Repowering Feasibility Study Northport

May 20, 2020

Repowering i Feasibility Contents Study

CONTENTS

Section Page

OVERVIEW ...... O-1

1. SCOPE, OBJECTIVES & APPROACH ...... 1-1

1.1 Scope & Objective ...... 1-1

1.2 Approach ...... 1-2

2. BACKGROUND & INPUTS ...... 2-1

2.1 Current Plant Description ...... 2-1

2.2 Current Plant Operations ...... 2-3

2.3 Condition of Existing Facilities ...... 2-6

3. A CHANGING ENVIRONMENT ...... 3-1

3.1 State Initiatives ...... 3-1

3.2 LIPA Commitments ...... 3-3

3.3 Existing Contracts & Resource need ...... 3-4

3.4 Peak Load Forecasts ...... 3-5

4. TECHNOLOGY EVALUATION & REPOWERING SCENARIOS ...... 4-1

4.1 Technology Evaluation ...... 4-1

4.2 Scenarios ...... 4-8

5. ENGINEERING & ENVIRONMENTAL ANALYSIS ...... 5-1

5.1 Engineering Considerations ...... 5-1 Proposed Repowering Option ...... 5-1 Repowered Unit Operating Performance ...... 5-2 Supply, Delivery, and Storage ...... 5-2

Repowering ii Feasibility Contents Study

CONTENTS

Section Page 5.2 Transmission System ...... 5-3

5.3 Environmental Considerations ...... 5-3 Project Licensing & Permitting ...... 5-3 Required Permits ...... 5-5 Permitting Studies ...... 5-7 Air Emissions and Water Characteristics ...... 5-8 Environmental Benefits of New Units ...... 5-8

5.4 Constructability ...... 5-9 Demolition ...... 5-10 Equipment Delivery ...... 5-10

5.5 Storm Protection ...... 5-10

5.6 Project Schedule ...... 5-11

6. REPOWERING PROVISIONS AND ECONOMIC VIABILITY ...... 6-1

6.1 Ramp Down and Repowering Provisions ...... 6-1

6.2 Economic Analysis ...... 6-3 Modeling Considerations ...... 6-3 Summary of Results ...... 6-5 Results for Grid Proposal (Scenario 3) ...... 6-7 Results for Repowering or Retirement of a Single Unit (Scenarios 1 and 6) ...... 6-8

6.3 Site Acquisition Options ...... 6-10 PSA Article 10 Capacity Ramp Down ...... 6-11 Schedule F – Grant of Future Rights ...... 6-11

7. IMPACT ON THE COMMUNITY ...... 7-1

7.1 Jobs ...... 7-1

7.2 Taxes ...... 7-1

Repowering iii Feasibility Contents Study

CONTENTS

Section Page 8. CONCLUSION ...... 8-1

9. ACRONYMS AND ABBREVIATIONS ...... 9-1

APPENDIX A: BENCHMARKING………...…………………………...………………………………...…A-1 APPENDIX B: RCMT CONDITION ASSESSMENT REPORT (REDACTED)…..………………...... …B-1 APPENDIX C: NORTHPORT REPOWERING ATTRIBUTES SUMMARY.…..………………...... …C-1 APPENDIX D: NORTHPORT REPOWERING PROJECT SCHEDULE (SCENARIO 3)...………...…D-1 APPENDIX E: PRODUCTION COST METHODOLOGY....………………………………...………...…E-1 APPENDIX F: MARKET FORECASTING METHODOLOGY………………………………...... …...….F-1

Repowering iv Feasibility Tables and Figures Study

TABLES AND FIGURES

Table or Figure Page

Table O-1: Repowering Scenarios: Capacity Retirements/ Additions ...... O-6 Table O-2: Increased Costs thru the Study Period (2020 – 2040) ...... O-8 Table 3-1: CLCPA Goals ...... 3-1 Table 4-1: Repowering Scenarios: Capacity Retirements/Additions ...... 4-10 Table 5-1: Disposition/Addition of Major Plant Assets: Scenario 3 ...... 5-1 Table 5-2: List of Permits and Approvals ...... 5-5 Table 6-1: Northport Unit Repowering Cost Impact in 2030 ...... 6-5 Table 6-2: Increased Costs thru the Study Period (2020 - 2040) ...... 6-6 Table 7-1: Peak Jobs Creation: Scenario 3 ...... 7-1

Figure 2-1: Northport Units: Historical Capacity Factors ...... 2-4 Figure 2-2: Northport Steam Units: Summer Equivalent ...... 2-5 Figure 3-1: LI Capacity Resources* ...... 3-5 Figure 3-2: LIPA Peak Load Forecasts ...... 3-6 Figure 4-1: NREL’s Direct Normal Solar Resource of ...... 4-3 Figure 4-2: NREL’s New York Average Speed at 80 m ...... 4-4 Figure 4-3: NREL’s Geothermal Resource of the ...... 4-5 Figure 4-4: NREL’s Mean Annual Power Density for Tidal ...... 4-6 Figure 4-5: NREL’s Wave Energy Potential ...... 4-6 Figure 4-6: NREL’s Potential ...... 4-7 Figure 4-7: Repowering Scenarios’ Timelines: Capacity Retirements/ Additions ...... 4-11 Figure 6-1: Increase in Annual Costs: Scenario 3 ...... 6-7 Figure 6-2: Composition of Increase in Annual Costs: Scenario 3 ...... 6-8 Figure 6-3: Capacity Excess Under Scenarios 1 and 6* ...... 6-9 Figure 6-4: Northport Trend ...... 6-10

Repowering O-1 Feasibility Overview Study

OVERVIEW

Chapter 58 of the Laws of 2015 enacted Senate Bill 2008-B and Assembly Bill 3008-B (the Bill) and directed the Power Authority (LIPA or the Authority), in cooperation with, its service provider, PSEG Long Island (PSEG LI), and the owner, National Grid (National Grid, Grid or GENCO), of the legacy LILCO power generating stations, to perform, or direct the performance of, engineering, environmental permitting, and cost feasibility analyses and studies (Repowering Study or Study) for repowering the E. F. Barrett (Barrett), Port Jefferson, and Northport power stations using “greater efficiency and environmentally friendly technologies.” The Barrett and Port Jefferson Studies were completed in April 2017. Upon completion of the Study, LIPA, if it were to find that repowering any of the noted generating facilities “…is in the best interests of its ratepayers and will enhance the [A]uthority's ability to provide a more efficient, reliable and economical supply of electric energy in its service territory…”, would exercise its rights under the Power Supply Agreement (PSA)1 related to repowering.

As required by the Bill, this Study evaluates repowering the Northport facility using more efficient and environmentally friendly technologies. It is not a broad assessment of all system-wide options available to LIPA. Accordingly, it is important to note that there are other potential options available to LIPA that might achieve the same or greater benefits, at a lower cost, as a Northport repowering. A full analysis of these options, however, falls outside the scope of this Study.

It is also important to recognize that LIPA’s typical process regarding changes to the electric system is to identify a need/problem/opportunity, then competitively solicit alternatives that best address the issue(s) at the lowest cost to customers. This repowering Study reverses this process by evaluating specific solutions first, an approach that is not optimal for solving today’s and future system needs.

Executive Summary

This report finds no compelling reason to repower the to maintain its existing production capacity. Moreover, all the repowering options studied will increase customer costs. While repowering Northport is technically feasible, its benefits do not outweigh its considerable costs. Repowering Northport would result in

1 Amended and Restated Power Supply Agreement dated October 12, 2012 between LIPA and National Grid. This Agreement pertains to Barrett, Port Jefferson, and Northport, among other units.

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a substantial increase in costs to customers versus the status quo which, depending on the repowering Scenario evaluated, ranges from approximately $1.2 billion to $2.1 billion.2

The station has become increasingly uncompetitive in the as manifested by a steady decline in its average capacity factor – from 55.8% in 2005 to 15.2% in 2019. The average capacity factor is forecast to further decline to 2.9% in 2035. Consequently, the most cost effective of the options studied is to retire a Northport steam unit, which would significantly reduce costs. Retirement - not a repowering – of just one of the four existing steam units results in savings to customers of approximately $303 million3 over the period 2020 to 2040 without jeopardizing reliability standards.

Six different scenarios, five associated with repowering and one, as mentioned, examining the retirement of a single unit, were analyzed as part of the Study. None of the repowering scenarios studied are of economic benefit to customers. Bills to customers would increase above where they would otherwise be under the status quo (i.e., the Reference Case) for all of the repowering scenarios evaluated and would decrease with a unit retirement. This finding is not surprising given the outlook for Long Island and the State overall that shows: 1) a current surplus of installed generating capacity that is expected to grow as new, clean renewable resources are added in response to state policy and legislation and; 2) load growth that is expected to decline until 2028 and then increase only gradually thereafter.

The changing market and regulatory conditions will be evaluated in detail in LIPA’s next Integrated Resource Plan (IRP), scheduled to begin in 2020. Results of the IRP will provide a roadmap for decisions regarding the deployment of new, clean energy on Long Island and the disposition of existing generation capacity.

LIPA has made no decision as yet regarding the retirement of additional steam plants (Northport, Barrett or Port Jefferson) beyond those at Far Rockaway and Glenwood that were retired in 2012. However, it is likely that results of analyses conducted during 2020 will indicate that additional closures, as early as 2022 – 2023, make economic sense. Consequently, the retirement of one or more of the steam units at Northport is more likely in the coming years than a repowering of the plant as long as the impacts on the reliability of power supply both for Long Island overall and for the local area served by the plant remain within acceptable criteria. Such a decision would be consistent with LIPA’s more recent decision to retire two units in 2020 and 2021.

2 Total Net Present Value (NPV) costs through the study period 2020 - 2040 of a full repowering (i.e., retiring and replacing all, or most, of the existing steam unit’s capacity) and assumed Power Purchase Agreement (PPA) type. 3 Total NPV savings assumes a reduction of approximately 25% of current property taxes. However, even assuming no change in property tax levels, it is still economically beneficial to retire at least one Northport unit.

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While additional renewable generation and are likely to be built on Long Island pursuant to the Climate Leadership and Community Protection Act (CLCPA), the optimal location for such resources will be determined through future system-wide studies and procurements. Accordingly, a decision now to install any new generation at Northport generating station is not in the best interests of LIPA’s customers.

The remaining sections of this chapter provide summary descriptions of the existing plant, the potential for deployment of renewable technologies at Northport, the repowering scenarios evaluated, and the key findings of the Study.

The Existing Plant

The Northport Power Station is located on Waterside Ave in the town of Huntington along the north shore of Long Island in Suffolk County, NY. The parcel of property totals approximately 250 acres of which only approximately 75 acres is land usable for repowering. The steam units include four dual-fuel Engineering boilers with four General Electric (GE) turbine-generators, each unit of 375 MW . Also on the site is a single 16 MW GE Frame 5 gas turbine, combining for a station total of 1,516 MW. The units at Northport are operated under the terms of the PSA and unit commissioning occurred on the following dates:

• Steam units 1, 2, 3, and 4 were commissioned in 1967, 1968, 1972, and 1977, respectively.

• The 16 MW GE Frame 5 gas turbine was commissioned in 1967.

Starting in 1993, the capability to burn was added to the steam units giving them the ability to burn either natural gas or . Natural gas is delivered by pipeline extension of the Local Distribution Company (LDC), Keyspan Gas East dba National Grid. The steam units are once-through cooled with water from the plant’s intake structure and discharge to . The electrical point of interconnection is to an onsite LIPA substation.

The station is economically dispatched by the NYISO but has become increasingly less competitive in the energy market in recent years as manifested by a steady decline in the steam units' average capacity factor. In 2005, the steam units’ average capacity factor was 55.8%, but only 15.2% in 2019. The station, though, is highly reliable as measured by its availability to operate, particularly during the critical summer months, June through August. In the summer periods from 2014 – 2019, the units were available to generate energy an average of over 96% of the time, significantly above a peer group average of about 88%.

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While the operation of the existing Northport steam units shows a steady and likely inexorable decline in capacity factor, its high level of availability, particularly for a plant with units commissioned in the 1960’s and 1970s, reflects National Grid’s sound and well-executed capital investment program and operations and maintenance philosophy. And while it is not possible to predict how the units will operate in the future, given past performance, current operation and maintenance practices, and reasonable expected levels of capital investment, the Study assumed, as part of the Reference Case analysis, that Northport could continue to operate reliably through 2040 when it would be shut down consistent with New York State’s recently enacted CLCPA mandate for 100% carbon free generation.4

Plant Ownership and Offtake Agreement

The Northport power station is owned by National Grid. LIPA is entitled to all of the power output of the plant under the terms of the Power Supply Agreement between Grid and LIPA, and has certain rights to approve and request investment projects, including repowering, and to retire units, with LIPA bearing the cost responsibility per the terms of the PSA. The contract expires April 30, 2028, at which point entitlement to the power output of the station reverts to National Grid. In the case of repowering, this study assumed that LIPA would enter into a long-term Power Purchase Agreement (separate from the PSA) for the power output of each of the repowered units.

Technology Evaluation

Given the relatively limited acreage available at Northport for development of renewable resources, the Northport repowering Study typically would not have examined the possibility of large-scale renewable development at the site. However, in recognition of CLCPA mandates, which effectively eliminate the use of all non- resources by 2040, an examination of the renewable energy potential at Northport was undertaken. A total of ten (10) renewable technologies were examined, including:

• Solar Photovoltaic • Solar Thermal • Onshore Wind • Hydroelectric • Geothermal

4 The CLCPA created numerous other mandates, among them that that 9,000 MW of offshore wind will be in developed by 2035 and that there will be 3,000 MW of energy storage in the state by 2030.

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• Tidal • Wave • Ocean Thermal • Fuel Cells • Offshore Wind

As described in Chapter 4, no renewable technology was deemed practical (exclusive of interconnecting offshore wind at Northport) or remotely sufficient in terms of potential development size to replace Northport’s current capacity largely due to the restrictive site size and/or lack of appropriate natural conditions at the site. This conclusion led to the need to develop repowering scenarios that included conventional generation.

Repowering Scenarios

The Study assessed the impacts of Grid’s base proposal (Scenario 3) to repower Northport plus five (5) other scenarios. These six scenarios were then evaluated against a Reference Case. The six scenarios and the associated technology configuration of each are depicted below in Table ES-1. Scenario 3 represents Grid’s proposal. The five other scenarios were:

• One (1) scenario that retires one Northport steam unit (375 MW), i.e., Scenario 6. • One (1) scenario that represents a repowering of a single unit, i.e., Scenario 1.

• One (1) scenario that represents close to a full repowering of existing capacity, i.e., Scenario 5.

• Two (2) scenarios that represent a full repowering of existing capacity, i.e., Scenario 2 & 4.

The Reference Case includes all existing and planned generating units with the exception of two small existing combustion turbines at other LILCO-era stations that have been announced for retirement. The economic analyses described in this report compare the annual revenue requirements for the Reference Case versus each of the six scenarios.

All scenarios use the same load forecast, projected fuel and emissions prices, and the same set of existing and planned generating resources aside from the retirements and/or additions specific to the scenario. The multiple scenario approach was adopted to provide a more robust range of potential solutions for a repowered Northport given the rapidly changing technology, market, and regulatory environments. Since no renewable technology, exclusive of interconnecting offshore wind at Northport was deemed practical (feasibility has not been determined), all replacement capacity was assumed to be either conventional gas-fired generation or batter energy storage systems (BESS or batteries).

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Table O-1: Repowering Scenarios: Capacity Retirements/ Additions

Scenario Unit Type/Status Unit Size 1 2 3 4 5 6

NP 1 (375 MW) Y Y Y Y Y Y

NP 2 (375 MW) --- Y Y Y Y --- NP Units to be Retired NP 3 (375 MW) --- Y Y Y Y ---

NP 4 (375 MW) --- Y Y Y Y ---

Net Existing Capacity 1,125 MW 0 MW 0 MW 0 MW 0 MW 1,125 MW

New CC 340 MW 1 ea. 2 ea. 2 ea. 1 ea. 2 ea. ---

New SC 230 MW --- 4 ea. 3 ea. 3 ea. 2 ea. ---

New BESS 50 MW 1 ea. --- 3 ea. 3 ea. 3 ea. ---

New OSW 800 MW* ------1 ea. ------

NNC Cable 229 MW ------1 ea. --- Upgrade

Added New Capacity 390 MW 1,600 MW 1,520 MW 1,580 MW** 1,290 MW*** 0 MW

New Northport Plant Capacity 1,515 MW 1,600 MW 1,520 MW 1,580 MW** 1,290 MW*** 1,125 MW

COD Range of New Capacity 2025 - 2026 2026 - 2032 2025-2034 2025 - 2034 2025 - 2034 ---

* Nameplate capacity; UCAP capacity is assumed to be ~400 MW ** Assumed UCAP capacity for offshore wind *** NNC cable upgrade does not count as UCAP capacity

Note that for each Scenario the units to be retired are indicated by a “Y” in the table. (The absence of a “Y” indicates that the unit is not retired.) The “Net Existing Capacity” row is the total capacity associated with the existing units post retirement(s). “Added New Capacity” represents the total new capacity added in each Scenario and is determined by summing the amount of capacity associated with the specific type and amount of new capacity in a Scenario. “New Northport Plant Capacity” is the sum of the “Added New Capacity” and “Net Existing Capacity.”

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Repowering an existing power plant is in some respects more complicated and time consuming than ground-up construction on a vacant property. The analysis indicates that the range of time for implementation of the complete complement of technologies for 4 of the 6 scenarios is between 12 and 14 years (starting from 2020). This extended period is largely due to limited site acreage and the consequent required staging of permitting and construction of the replacement capacity, and the demolition activities associated with the existing capacity. The extended period also has a significant impact on the time available (it is reduced) for Grid to recover project costs under the assumption that natural gas fired generation cannot be part of the State’s resource supply mix from 2040 onwards per the CLCPA. The shortened period to recover costs associated with conventional generation translates to increased costs when compared to recovering costs over a time period that extends beyond 2040.

As indicated, Grid developed and provided pricing proposals for new combined cycle units, simple cycle units, and batteries (i.e., Scenario 3). Those pricing proposals formed the basis for financial analysis of the other scenarios. Grid’s pricing included, among other things, fixed annual capacity payments, fixed O&M payments escalated annually, and variable operations and maintenance charges. Provision of fuel would be the responsibility of LIPA. The financial analysis of the Northport repowering options was based on a model used for LIPA’s financial projections. It was assumed that the repowered plant’s annual taxes would remain the same as that incurred on the existing plant.5

Considering the CLCPA’s goals – 100% carbon free electricity production by 2040 – in general, current resource planning activities aim to eliminate the use of conventional generation fired by fossil by 2040.6 This introduced a complication into the Study. Given that there is a restriction by 2040 on the use of carbon-based fuels, it raises a question about what contract term should be assumed for a project that is part of a repowering. To deal with this issue (i.e., contract term), the Study analyzed the effects of contracts for non-renewable resources that expired by 2040 with full recovery of project costs by that time, and standard 20-year contracts for non- conventional technologies that would expire post 2040, which allows for cost recovery over the entire 20-year contract term.

5 Scenario 6, retirement of a single Northport steam unit, did assume an annual reduction in taxes of approximately 25 percent. 6 It does not eliminate, however, conventional generation fired by a renewable fuel, such as hydrogen or a liquid fuel derived from .

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Findings

The key findings of the results of the Northport repowering Study are presented in conformance with the requirements of the Bill. They are as follows:

• A repowering of the Northport power station using only renewable technologies to replace the plant’s existing capacity is not feasible from a technical perspective due to restrictive site acreage and/or lack of favorable natural conditions at or in the vicinity of the site.

• A repowering of the Northport power station using conventional technology (i.e., natural gas-fired generation) as part of a repowering configuration is feasible from a technical and environmental permitting perspective but is not economic (i.e., it increases costs to ratepayers).

• The total aggregate cost impact of a complete, or near complete, repowering (Scenarios 2 - 5), or partial repowering (Scenario 1) is significant and varies by assumed PPA length. The table below provides a summary of the incremental increase (or decrease in the case of a single unit shutdown – Scenario 6) in total costs and in the total bill impact for a typical residential customer under each scenario when compared to the Reference Case.

Table O-2: Increased Costs thru the Study Period (2020 - 2040)

Total Incremental Costs (NPV: $millions)

Scenario

PPA Type 1 2 3 4 5 6**

20-Year $682 $1,704 $1,616 $1,220 $1,569 ($303)

Full Recovery $770 $1,982 $2,081 $1,470 $1,948 ($303) by 2040*

Total Incremental Residential Bill Costs ($)

Scenario

PPA Type 1 2 3 4 5 6**

20-Year $597 $1,565 $1,480 $1,092 $1,436 ($263)

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Full Recovery $663 $1,794 $1,894 $1,301 $1,768 ($263) by 2040*

* Only for technologies using . ** Unit 1 retirement only. There is no associated PPA with Scenario 6. Results are based upon a reduction of approximately 25% in Northport property taxes

o Retirement of a single unit at Northport (Scenario 6) results in an incremental decrease in the net present value of total costs as well as a total bill reduction for a typical residential customer.

o Retiring a single steam unit and replacing it with new conventional combined cycle technology (Scenario 1) increases total costs in the range of $0.7 to $0.8 billion.

o The net present value of the incremental total cost increase over the Study Period associated with a complete or near complete repowering of Northport (Scenarios 2 – 5) ranges from approximately $1.2 billion to $2.1 billion depending on replacement technology type.

o The total incremental bill impact for a typical residential customer over the Study Period associated with a complete or near complete repowering of Northport (Scenarios 2 – 5) ranges from approximately $1,100 to $1,900 depending on replacement technology type.

• The existing Northport steam units have shown a relatively steady drop in average capacity factor, declining from a high of 55.8% in 2005 to a six-year average (2014 – 2019) of 18.2%.7 Seasonal variations include higher summer-month operations (recent capacity factors of approximately 30%) and peak winter-month operations when ambient temperatures are low. During spring and fall months, capacity factors are very low. The utilization of the steam units is expected to continue to decline as increased amounts of renewable resources are added to the system.

• An independent plant condition assessment indicated that the existing Northport units are well maintained, reliable for their age, and with reasonable projected capital and operations and maintenance expenditures can maintain their reliability for the foreseeable future.8 The condition

7 A capacity factor of 100% means that a plant would be operating at its full capacity every hour of the year. 8 “Condition Assessment of National Grid Electric Generation Assets, Technical Report,” and “Projections of Capital and O&M Expenditures for National Grid Electric Generation Assets”; RCM Technologies, Inc., December 30, 2014.

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assessment results are consistent with recent operating performance. Overall, Northport’s operating performance compares favorably to similar units in operation during recent years (2014 – 2019).

• Repowering conventional units typically makes the most sense where the fixed and variable costs of continuing to operate the older units is high compared to the costs for new technology. Major drivers usually include the relatively high cost of fuel for inefficient older units and the associated relatively high fixed costs of new technology. However, under current conditions where projected gas prices are quite low by historic measures and considering the low expected capacity factors for the steam units over the study period, fuel cost savings of new units, and their high fixed costs, do not provide a compelling reason to pursue Northport repowering using conventional technologies. Whether Northport could be a good site for installation of energy storage or interconnection of offshore wind is a question that remains to be answered by competitive procurements to occur in 2020 and beyond, as well as through further studies.

• Significant uncertainty exists around the size, timing, type, and location of new renewable generation to be built on or around Long Island pursuant to the CLCPA. Also, energy efficiency and the growth in distributed energy resources, such as rooftop solar, have significantly reduced LIPA’s forecasted need for new generation. For example, the preliminary 2020 peak-load forecast for 2030 is over 2,500 MW less than the forecast for 2030 prepared in 2013, resulting in a peak load forecast reduction of over one and one-half times the size of the proposed Northport repowering.

• The current size of the generation portfolio on Long Island is greater than current needs and is projected to remain so for the foreseeable future. This excess provides significant redundancy and flexibility to meet changing but currently uncertain needs. New, long term commitments to generation now would reduce the flexibility to respond to changing conditions.

• The Study assumed property taxes associated with the repowering scenarios would remain at the same level as the status quo,9 which currently are multiple times the level paid on a per megawatt-hour basis for another combined cycle plant (Caithness) installed on Long Island.

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9 Scenario 6, retirement of a single Northport steam unit, did assume an annual reduction in taxes of approximately 25 percent.

Repowering 1-1 Feasibility Scope, Objectives & Approach Study

1. SCOPE, OBJECTIVES & APPROACH

Chapter 58 of the Laws of 2015 enacted Senate Bill 2008-B and Assembly Bill 3008-B (the Bill) directing the Long Island Power Authority (LIPA or Authority), in cooperation with, its service provider, PSEG Long Island (PSEG LI), and the owner, National Grid (National Grid, Grid or GENCO) of the legacy LILCO power generating stations, to perform an engineering, environmental permitting and cost feasibility analysis and study (Repowering Study or Study) of repowering the Northport Power Station (Northport). Further, the Bill required LIPA to study repowering utilizing greater efficiency and environmentally friendly technologies.

1.1 SCOPE & OBJECTIVE

The scope of the Study was to perform an engineering, environmental permitting, and cost feasibility analysis of the potential repowering of Northport. The Study includes the system-wide energy and capacity impacts that result from such a repowering and makes assumptions regarding important local issues such as property taxes. Importantly, while the analysis included the impacts of exogenous factors, such as compliance with the State’s goal of 70 percent renewable energy by 2030 (i.e., 70 x 30), it does not fully reflect the State’s goal of 100 percent carbon free electricity production by 2040 (i.e., 100 x 40).10 The 2040 goal was not modeled due to the significant uncertainty surrounding numerous other impactful factors, such as the load forecast, under a 100 x 40 scenario. Nevertheless, the results are considered conservative (i.e., more economically favorable) regarding a repowering of Northport because meeting the 100 x 40 goal would introduce additional, low marginal cost renewables into the system, thereby making a repowered Northport less economically attractive.

As required by the Bill, this Study exclusively evaluated repowering the Northport facility using more efficient and environmentally friendly technologies. It was not a broad assessment of all system-wide options available to LIPA, some of which might produce environmental and efficiency effects similar to or perhaps greater than those achieved by repowering Northport, but at a lower cost. For example, in lieu of repowering Northport, an alternate investment to build a new renewable energy facility, such as offshore wind, or a new simple or combined cycle facility at a different location, or simply retiring Northport and upgrading the proximate transmission system infrastructure (thereby eliminating all local power plant emissions), may be more cost effective and environmentally friendly than repowering Northport. Accordingly, it is important to note that there are other potential options available to LIPA that might achieve the same or greater benefits at a lower cost than a Northport repowering. However, a full analysis of these options falls outside the scope of the Study.

10 The Reference Case results in approximately 91% emissions free electricity production statewide by 2040.

Repowering 1-2 Feasibility Scope, Objectives & Approach Study

The objective of the Study was to provide the LIPA Board of Trustees with the necessary background and analyses regarding the potential repowering of Northport. As stated in the Bill, the Study is intended to support LIPA in determining if repowering “…is in the best interests of its ratepayers and will enhance LIPA’s ability to provide a more efficient, reliable, and economical supply of electric energy in its service territory...” It should be noted that while this report is not intended to represent final repowering design or cost parameters, the results reflect realistic representations of potential plant design and cost characteristics.

1.2 APPROACH

The Study is structured to address the following questions in the context of its objectives:

• Is repowering Northport technically feasible, environmentally friendly, and economically viable? • Is now the optimum time for deciding when and how to repower Northport, if it is deemed beneficial?

The Study developed the following framework to address the questions and uncertainties associated with repowering: • Define a Reference Case against which potential repowering scenarios could be evaluated. • Define the repowering scenarios to be considered. • Provide the background and information required to assess the repowering scenarios. • Assess repowering engineering characteristics and issues, such as:

o What facility changes would result from repowering? o What are the repowered plant performance characteristics? o What changes are required to fuel the repowered plant? o What changes are required to connect the repowered plant to the electric grid, and assess the ability to export and transmit power on the grid? • Identify and address the environmental considerations for the repowered facility, such as

o The permits required to build and operate the repowered facility. o The studies required to obtain the necessary permits. • Identify and assess miscellaneous project implementation issues, such as:

o Constructability considerations. • Assess the economic viability of the repowering project, considering such items as:

o Electric load forecasts and expected plant dispatch characteristics. o PSA ramp down and repowering provisions.

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o Financial cost to LIPA’s customers. • Assess the impact on the community of a repowering project

In addition to the analyses, assessments and considerations above, the Study also considered the changing environment in which the decision to repower Northport would be made. These conditions, such as the recently enacted CLCPA, ongoing New York State energy initiatives, and evolving environmental policies and regulations, result in significant uncertainty as to future electric grid needs. Accordingly, the Study considered the time frames for when current uncertainties might be clarified versus the expected remaining life (i.e., ongoing reliable operation) of the current power plant.

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Repowering 2-1 Feasibility Background & Inputs Study

2. BACKGROUND & INPUTS

Under the Amended & Restated Power Supply Agreement (PSA) between LIPA and Grid, LIPA purchases capacity and energy from Grid from a fleet of steam and combustion turbine generating units aggregating approximately 3,700 MW. Within this fleet are eight steam generating units located at three sites totaling approximately 2,350 megawatts. Those three sites are the Northport, Port Jefferson and Barrett power stations. Grid also owns and operates 41 combustion turbine generating units at ten sites totaling approximately 1,350 MW. These ten sites are inclusive of the three steam generating stations. As such, all three steam generating stations also host combustion turbine generators.

This Chapter presents a description of the existing Northport generating station facilities and its current operations, as well as an assessment of current plant conditions. Of note is that while substantial assets remain dedicated to specific generating units at any given site, there may be significant shared assets at a site, including fuel handling facilities, buildings, certain switchyard equipment, and other balance of plant (BOP) structures and facilities. Consequently, repowering a generation plant – such as Northport - where the entire station cannot be shut down simultaneously presents construction sequencing challenges to allow some existing units to remain in service while other units are retired and demolished. This tends to extend the time required to complete a repowering, particularly so at Northport where construction sequencing is further challenged by site acreage constraints.

The Study used existing applicable and relevant information consisting of the current plant configuration and capabilities, repowering options and corresponding key attributes, and assumptions required to analyze relevant engineering, economic, and environmental factors, all of which are identified in the Study.

2.1 CURRENT PLANT DESCRIPTION

The Northport Power Station is located on Waterside Ave in the town of Huntington along the north shore of Long Island in Suffolk County, NY. The parcel of property on which Northport is located totals approximately 250 acres, of which approximately 75 acres is usable for a repowering. The steam units include four dual-fuel boilers with four General Electric (GE) turbine-generators each of 375 MW nameplate capacity. Also onsite is a single 16 MW GE Frame 5 gas turbine, combining for a station total of 1,516 MW. The units at Northport are operated under the terms of the PSA and were commissioned on the following dates:

• Steam units 1, 2, 3, and 4 were commissioned in 1967, 1968, 1972 and 1977, respectively.

• The 16 MW GE Frame 5 gas turbine was commissioned in 1967.

Repowering 2-2 Feasibility Background & Inputs Study

Starting in 1993 the capability to burn natural gas was added to the steam units, giving them the ability to burn either natural gas or fuel oil. The units were converted to burn natural gas per the following schedule;

• Unit 1- June 1998

• Unit 2- May 1995

• Unit 3- February 2003 (partial), May 2008 (full)

• Unit 4- May 1993

The steam units are fueled with both 0.5 percent low No. 6 oil and natural gas. Natural gas is supplied to the four steam units by a common Iroquois high pressure 1,400 psig gas pipeline and a common meter and regulating station that reduces pressure to 300 psig. No. 6 fuel oil is delivered to the steam units via ship through an offshore unloading terminal approximately two miles from the site in the Long Island Sound. The simple cycle gas turbine is fired on No. 2 fuel oil only, delivered through the same offshore unloading facility as No. 6 oil for the steam units. Makeup water to the station is supplied by water supply that is processed through a common demineralizer and system for the four steam units.

Northport has five tanks for storage of No. 6 fuel oil, but tanks 1 through 3 have been drained and retired. Tanks 4 and 5 remain in service. The No. 2 oil for the gas turbine unit is stored in a separate, dedicated tank. As per the arrangements between LIPA and Grid, stored fuel oil is owned by LIPA.

The Northport site is the tie point for a submarine transmission cable connecting across Long Island Sound to Norwalk Harbor in Connecticut. These cables enter the site north of the existing substation. The Iroquois natural gas pipeline traverses the site along with the Eastchester line that leaves the site and is routed under the Long Island Sound. The existing units are once-through cooled with intake from the Northport basin and discharge through a discharge canal to the Long Island Sound. The electrical point of interconnection is to an on-site 138kV LIPA substation.

PSEG LI maintains the station’s switchyard and LIPA owns the main power and the high side going to the switchyard. Grid owns the low side power line up to the main power as well as startup and auxiliary transformers. Among numerous plant systems and equipment, Units 1 & 2 and Units 3 & 4 have, for example, separate control rooms, AC and DC electrical systems, balance of plant air supply, and circulating water and steam supply.

Repowering 2-3 Feasibility Background & Inputs Study

Since certain repowering scenarios require the staged demolition of Northport units and the construction of new units, it is important to recognize that there are certain common equipment and facilities among the units at Northport. Such common equipment and facilities include, for example:

. Natural gas supply line, gas heaters, filters and meter and regulating station – shared across the steam generation units. . Fuel oil offshore unloading dock (located in the Long Island Sound) and supply shared across the steam generating units and the GT unit. . Fuel oil tanks 4 and 5 are shared among the steam units. . Turbine building for the steam units with two overhead turbine cranes . Common circulating water discharge dilution pumps and piping, which are required to maintain the circulating water discharge permit temperatures in the discharge channel for the steam units. . Service water system with two pumps per unit . Station waste-water facility . water protection system with storage tank supplied by city water and common fire pumps for the station . Building heating . Station security fencing and cameras . City water supply and associated demineralizer water system with each unit having a condensate storage tank with cross tie capability . Emergency electrical generators (2) . Soot blower air compressor

Disposition of all of the above equipment and systems was considered when developing the repowering buildout and schedule.

2.2 CURRENT PLANT OPERATIONS

The station is economically dispatched by the NYISO. Each steam unit normally operates from a minimum load of 100 MW to a design load of 363 MW. The guaranteed ramp rate in the normal operating range is 4 MW per minute. The station provides ancillary services in the form of voltage support services, frequency regulation, and 10-minute synchronous reserve response. The full-load heat rate for Units 1, 2, 3, and 4 is approximately 10,200 Btu/kWh when burning natural gas.

Repowering 2-4 Feasibility Background & Inputs Study

The steam units follow a seasonal operational trend. Seasonal variations include higher summer-month and peak winter-month operations when ambient temperatures are high and low, respectively. During the spring and fall months, capacity factors, conversely, are low.

To assess the performance of the Northport steam units, they were compared to 25 comparable steam units operated by 19 other utilities during the period 2014 through 2019. Details of the benchmarking comparison are provided in Appendix A.11 Of the key performance statistics, relevant comparisons include those for Equivalent Availability Factor (EAF), Capacity Factor (CF), and Equivalent Forced Outage Rate – demand (EFORd). These factors and rates provide a consistent way to compare the performance and condition of comparable power generation units. CF is defined as the ratio of a unit’s actual output over a period of time to its potential output if it were to operate at full capacity continuously over the same period of time; EAF indicates the percentage of time the unit is able to run, accounting for both planned and unplanned down time; and EFOR-d indicates how often a unit cannot run when it is called to run, which is typically considered the best indicator of a unit’s reliability.

As shown in the Figure 2-1, below, the Northport’s station’s net capacity factor shows a relatively steady decline from a high of 55.8% in 2005 to 15.2% in 2019. However, a comparison of recent (2014 – 2019) CF performance between Northport and the peer group shows Northport with a six-year average of 18.2% versus 9.0% for the peer group.

Figure 2-1: Northport Steam Units: Historical Capacity Factors

100

80

60

40

20 Capacity Capacity Factor (%)

0 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018

Northport Steam Units Peer Group 6-year Average (Steam)

11 Note that the “20 utilities” and “29 units” shown in Appendix A include National Grid and the four (4) Northport steam units.

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Equivalent Availability Factor (EAF) combined with the operating philosophy for a unit can be used to better understand a unit’s performance. Given the higher demand for electricity in the summer months, Grid works to maximize EAF from June 1 through August 31. Accordingly, it will schedule planned outages and major unit overhauls during the fall, winter, and spring months. Figure 2-2 shows Northport’s EAF during the three summer months during the years 2014 - 2019.

Figure 2-2: Northport Steam Units: Summer Equivalent Availability Factor

Peer Group 6-Year Average (87.73%) 100 90 80 70 60 50 40

Summer EAF (%) Summer 30 20 10 0 2014 2015 2016 2017 2018 2019 Northport - ST Unit 1 Northport - ST Unit 2 Northport - ST Unit 3 Northport - ST Unit 4

Northport’s EAF performance from 2014 - 2019 for the months of June, July and August was excellent, averaging 96.8% compared to an annual EAF of 87.7% for the peer group (a higher percentage is better), and reflects the results of Grid’s sound operating and maintenance philosophy. These EAF values also are consistent with Northport’s annual average EFOR-d performance for the same period, a low 3.55%, comparing favorably to the peer group mean of 13.09% (a lower percentage is better) and supports the independent condition assessment prepared by RCM Technologies, Inc. (RCMT) described below in Section 2.3.

Northport steam units operate in compliance with all required permits. There are multiple permits issued by the New York State Department of Environmental Conservation (NYSDEC), primarily covering air emissions, water use and discharge, and storage of liquid fuel. The air permit sets limits based on pollutant and fuel type. (SO2) emissions are directly proportional to the sulfur content of the residual fuel oil; the current limit is a maximum sulfur content of 0.5%. Though there is no unit specific NOx emissions rate limit for these units, there

Repowering 2-6 Feasibility Background & Inputs Study

is a regulatory target of 0.15 lbs/MMBtu regardless of fuel. On gas, these units typically operate at 40% - 50% below the regulatory target. When combusting No. 6 fuel oil, the units normally emit about 0.15 lbs/MMBtu NOx. Water discharges are limited for various physical and chemical constituents, typically pH, oil and grease, total suspended solids and various metals. Air emission and water discharge data are reported to the US Environmental Protection Agency (USEPA) and/or the NYSDEC on quarterly and monthly basis with any permit limit exceedances noted. The information is available to the public on various government databases. The steam units are once-through cooled with seawater from the plant’s intake structure and discharged to Long Island Sound. Aquatic protection for the cooling water intake system has been approved by the NYSDEC and technologies and operational controls are in place to minimize adverse impacts.

In terms of major capital expenditures, the circulating water screen system 316b capital upgrade for Units 3 and 4 has been completed. The circulating water screen system 316b capital upgrade for Units 1 and 2 has been approved with work scheduled to be complete on Unit 1 in the fall/winter of 2021/2022 and on Unit 2 in 2021. In addition, the Unit 4 major overhaul was completed in February 2019.

2.3 CONDITION OF EXISTING FACILITIES RCMT performed a high-level condition assessment in 2014 of Grid’s power generation units under contract to LIPA through the PSA, which included the Northport units.12 Overall, the condition assessment determined that the units could reliably operate at least until expiration of the PSA contract in 2028. This conclusion was based in part on Grid’s continued application of its capital and Operations & Maintenance (O&M) programs, which determine how much will be spent on specific systems, maintenance issues, and capital projects, its Condition Assessment Program (CAP), and its Root Cause Analysis (RCA) program.

Grid confirmed that the programs noted above are still in place, the inspections/major overhauls described in the report occurred without finding significantly adverse conditions, and that the O&M and capital spending levels have either been implemented as planned or changed in accordance with CAP and RCA program requirements. The benchmarking report provided in Appendix A shows that the operational performance of the Northport units compares favorably to similar units, further supporting the conclusions of the RCMT assessment. Accordingly, the conclusions reached in the RCMT high level condition assessment – even though performed in 2014 - are considered to remain valid and the Northport plant can reasonably be expected to operate reliably at least through the termination of the PSA contract and into the 2030s.

LAST PAGE OF CHAPTER 2.

12 See Appendix B for a redacted version of the RCMT’s report.

Repowering 3-1 Feasibility A Changing Environment Study

3. A CHANGING ENVIRONMENT

Cost, efficiency, reliability, and environmental characteristics are critical elements when considering whether to move forward with a new power plant. They are not, though, the only factors. In addition, consideration, particularly in New York, must be given to the breadth and magnitude of ongoing changes in the generation, transmission, and distribution sectors. These changes have a significant impact on decision making relative to repowering Northport, or any other plant on the system. The type and nature of key changes, and their attendant uncertainties, are presented below. In this Chapter we also discuss LIPA’s existing capacity and resource need in view of the changing environment.

3.1 STATE INITIATIVES

The State has several important, ongoing initiatives related to the electric generation sector. These initiatives include: • Climate Leadership and Community Protection Act (CLCPA): The CLCPA was signed into law in July 2019 and establishes some of the most aggressive clean energy and GHG reduction goals in the nation. The CLCPA effectively puts New York on a path towards carbon neutrality. A list of some of the major goals established by the CLCPA are listed in Table 3-1 below.

Table 3-1: CLCPA Goals

CLCPA Goal

85% reduction in GHG emissions by 2050

40% reduction in GHG emissions by 2030

100% carbon free by 2040

70% electricity generation from renewable energy resources by 2030

9,000 MW of offshore wind by 2035

3,000 MW of energy storage by 2030

Repowering 3-2 Feasibility A Changing Environment Study

6,000 MW of distributed solar by 2025

185 trillion BTU increase in on-site energy savings by 2025

• State Energy Plan (SEP): Intended to coordinate all State agencies’ efforts affecting energy policy to advance the REV agenda. On December 18, 2019, the NYS Board approved issuing a Draft Amendment to the 2015 State Energy Plan, to incorporate the new clean energy goals established under the Climate Leadership and Community Protection Act.

• Reforming the Energy Vision (REV): A Public Service Commission (PSC) policy framework intended to reorient and reform both the electric industry and the ratemaking paradigm toward a consumer-centered approach that harnesses technology and markets and is consistent with the SEP.

• NYSERDA’s New York State Offshore Wind Master Plan (Master Plan): The Master Plan was released by NYSERDA in January 2018 and presented the State’s comprehensive roadmap to encourage the development of 2, 400 MW of offshore by 2030. The offshore wind goal has since been increased to 9,000 MW by 2035 via the CLCPA.

• Clean Energy Standard (CES): A PSC Order issued in August 2016 adopting the SEP goal that 50% of New York’s electricity is to be generated by renewable sources by 2030. The goal has now been increased to 70% by 2030 through the CLCPA.

• Offshore Wind (OSW) Standard (OSW Standard): A PSC Order issued in July 2018 adopting the state’s goal of developing 2,400 MW offshore wind by 2030. The goal adopted by the OWS Standard has been expanded to 9,000 MW of offshore wind by 2035 through the CLCPA.

With the CLCPA now signed into law, New York has a clear direction on the environmental performance that will be expected of its power system in the future - that is, 70% electricity generation from renewable energy resources by 2030 and 100% carbon free electricity generation by 2040. The CLCPA goal of an 85% reduction in statewide GHG emissions by 2050 also indicates that there almost certainly will be a significant

Repowering 3-3 Feasibility A Changing Environment Study

increase in the electrification of New York’s economy and a consequent demand for even greater amounts of carbon free electricity. Nevertheless, while the CLCPA goals put New York on a path towards carbon neutrality, there still is a high degree of uncertainty as to the implementation plans associated with it and other related State-level initiatives. It is expected that it will take a few years for these plans to fully unfold and for their market and system implications to be fully understood.

Despite the uncertainties, initiatives in support of these ambitious CLCPA goals are moving forward and will have a major impact on New York’s power system. For example, the CLCPA’s 9,000 MW goal of offshore wind by 2035 creates a focus on offshore wind development off of Long Island. In furtherance of that goal, NYSERDA completed an initial solicitation in October 2019 executing two contracts totaling 1,696 MW of offshore wind, 880 MW of which will be injected into Long Island. The continued development of New York’s offshore wind resources is expected to bring major operational changes to LIPA’s transmission and distributions system.

The types, amounts, and location of new generation, energy storage, , or other distributed technologies that may be required to meet all of the CLCPA goals are yet unknown but, if the goals are met, are likely to result in an electric system significantly different than the current configuration.

3.2 LIPA COMMITMENTS

LIPA has been working for years to bring clean energy to Long Island and is committed to supporting the goals of the CLCPA. For example:

• In 2016, LIPA issued a Feed-in-Tariff (FIT) solicitation for commercial solar photovoltaics (i.e., FIT III). As of January 31, 2020, there were 35 commercial solar photovoltaics projects totaling 20 MW accepted into the FIT III program.

• LIPA’s PPA with Orsted adds 130 MW of offshore wind from the South Fork Wind Farm.

• LIPA’s 2015 Renewables RFP resulted in the selection of two solar photovoltaic projects, a 22.9 MW project that was recently approved by the LIPA Board of Trustees and a 36 MW project that is in Article 10 proceedings.

Repowering 3-4 Feasibility A Changing Environment Study

• In 2020, LIPA intends to issue a new solar communities’ FIT program (i.e., FIT V) for the interconnection of up to 20 MW of photovoltaic resources, and recently issued an RFI requesting input from interested parties on the development of an energy storage resources RFP to be issued later in 2020 for up to 175 MW of energy storage capacity by 2025.

In addition to the above initiatives, LIPA continually evaluates its position in the market, its resource need, and its renewable goals and commitments, all of which are affected by the CLCPA and other related State- level programs and market initiatives.

3.3 EXISTING CONTRACTS & RESOURCE NEED

Due to the uncertainty in the next several years over the pace, timing, and magnitude of technology, market and regulatory changes there is a significant benefit to LIPA to keep open as many options as possible to enable selection of the best choices for meeting its obligations at the lowest cost for its customers. Figure 3- 1 illustrates the flexibility LIPA has to defer making significant capital decisions until there is more certainty in policy and regulatory requirements, as well as to take advantage of ongoing technology and industry development. Notably, under the assumed conditions, LI has excess capacity for reliability purposes at least thru 2040.

Repowering 3-5 Feasibility A Changing Environment Study

Figure 3-1: LI Capacity Resources*

8,000

7,000

6,000

5,000

MW 4,000

3,000

2,000

1,000

- 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040

Capacity under Contract Merchant Capacity OSW Additions Capacity Requirement

*For the purpose of the economic analysis, it was assumed that the terms and conditions of the PSA would extend through 2040.

3.4 PEAK LOAD FORECASTS

The first and foremost goal of LIPA is to maintain system reliability. Doing so efficiently, economically, and in an environmentally sensitive manner is also critical. Maintaining a reliable system is underpinned by having the appropriate amount of reliable generating capacity, or access to such capacity, to serve anticipated load and having the ability to deliver the energy to the customer. In terms of the need for capacity, a key input is the long-term peak load forecast. The forecast provides a planning target that, along with other factors, dictates the need (or not) for additional capacity. As shown in Figure 3-2 below, LIPA’s peak load forecasts reveal dramatic year-on-year declines over the past seven years.

Repowering 3-6 Feasibility A Changing Environment Study

Figure 3-2: LIPA Peak Load Forecasts

8,000 2010 Forecast

7,500 2013 Forecast

2014 Forecast 7,000

2015 Forecast 6,500 2016 Forecast

6,000 MW 2017 Forecast Actual Peak 2,538 MW 2018 Forecast 5,500 2019 Forecast 5,000 2020 Forecast 4,500 (Prelim)

4,000 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036 2038

Econometric forecasts for Long Island (e.g., number of households, employment, gross metro product) and the projected increase in electric vehicles penetration provide impetus for increasing electric demand in the foreseeable future. However, this growth is expected to be more than offset during the next decade by the impacts of increasing penetration and effectiveness energy efficiency, renewables (behind-the-meter solar PV and batteries), and load modifier programs leading to dramatic reductions in peak load and energy forecasts vis a vis earlier years. For example, the peak load forecast for 2030 has been reduced by 2,538 MW when comparing the 2013 forecast to the preliminary 2020 forecast. The result of these changes is that based on reliability considerations and assuming LIPA’s current generation portfolio remains in place, LIPA has significant surplus capacity through 2040. Consequently, exclusive of local conditions, system reliability considerations do not drive a need for a repowered Northport.

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Repowering 4-1 Technology Evaluation & Feasibility Repowering Scenarios Study

4. TECHNOLOGY EVALUATION & REPOWERING SCENARIOS

The Northport repowering analysis was conducted in a political, regulatory and economic environment significantly different than that associated with the Barrett and Port Jefferson repowering studies. Politically, New York State has made substantial changes to its renewable energy and emission reduction goals since 2017, most notably through the recently enacted CLCPA. The specifics of the CLCPA are discussed in Chapter 3, Changing Environment, but certain aspects, such as achieving 70% of total state-wide electricity production from renewable sources by 2030 and 100% carbon free emissions from electricity production by 2040, provide ample evidence of the aggressive nature of the State’s goals. The regulatory environment also has become more active as state agencies intensify their efforts to rapidly develop plans and processes to successfully execute state goals. And economically, continued cost declines in renewable technologies are underpinning the growing penetration of renewable energy into the state’s and the nation’s resource mix.

In recognition of CLCPA mandates, which effectively eliminate the use of all carbon emitting energy resources by 2040, it was necessary to first understand whether there was the potential to employ renewable resources at the Northport site and, if so, to what degree. Following that assessment, repowering scenarios were developed that reflected the reality of feasible and economic implementation of repowering technologies, as well as practical site considerations (e.g., available usable acreage).

The following sections describe the results of the renewable technology evaluation that was conducted and the repowering scenarios that were subsequently developed.

4.1 TECHNOLOGY EVALUATION

Given that any repowering of Northport needs to take into account CLCPA goals, the potential for renewable energy production at Northport from a variety of technologies was evaluated. PSEG LI and Grid contracted with Power Engineers, a leading engineering design and evaluation firm, to examine the practical potential of deploying any of ten (10) different renewable technologies at Northport. The ability to deploy conventional technologies at Northport was a ‘given’, since gas-fired steam units and a combustion turbine unit currently exist at the site. The renewable technologies examined included the following:

• Solar Photovoltaic

Repowering 4-2 Technology Evaluation & Feasibility Repowering Scenarios Study

• Solar Thermal • Onshore Wind • Hydroelectric • Geothermal • Tidal • Wave • Ocean Thermal • Fuel Cells • Offshore Wind

The following provides brief descriptions of the potential application at the Northport site of the technologies identified above.

Solar Photovoltaic

The Northport site is a relatively flat site that according to the National Renewable Energy Laboratory (NREL) is in the higher range of solar irradiation when compared to the rest of New York State, as shown in Figure 4-1.

Repowering 4-3 Technology Evaluation & Feasibility Repowering Scenarios Study

Figure 4-1: NREL’s Direct Normal Solar Resource of New York

On average, solar installations require approximately 5 acres to support the installation of 1 MW of solar panels. The Northport site, though, has approximately 75 acres of usable land area (this includes the footprint of structures subject to demolition). Therefore, the approximate maximum capacity for the site is 15 MW, which is only 1% of existing plant capacity, a de minimis amount in the context of a full repowering.

Onshore Wind

The Northport site is conducive for onshore wind installations given its location along the coastline. As noted in the NREL map below, the site has a moderate average wind speed compared to the rest of New York State.

4-4 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

Figure 4-2: NREL’s New York Average Wind Speed at 80 m

Wind turbines require approximately 9 rotor diameters spacing between turbines to avoid impacting each other. Onshore wind turbines of approximately 2 MW each are typical for this type of locations. Given the spacing requirements and shape of the site, it could at most support two 2 MW turbines, totaling 4 MW of capacity, again negligible in amount compared to the site’s existing capacity.

Hydroelectric

The Northport site is approximately 7ft above level (ASL), therefore it does not have potential for generating hydroelectric power.

Geothermal

As noted from the map below, NREL gives the Long Island Area a “Least Favorable” rating for potential geothermal resources. There seems to be little to no potential for installing a generation resource of significant size at the Northport site.

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Figure 4-3: NREL’s Geothermal Resource of the United States

Tidal Energy

Tidal energy is charted by NREL and provided through its Marine and Hydrokinetic Atlas (Atlas), an interactive mapping tool designed and developed by NREL to help explore the potential for marine and hydrokinetic resources. The Atlas was used to obtain the map below.

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Figure 4-4: NREL’s Mean Annual Power Density for Tidal Energy

As noted from the data presented, the mean annual power density for tidal energy in the Long Island Sound is at the low end of the scale. Given the site’s location in the Long Island Sound, there is little to no potential for the installation of a Tidal at the Northport station.

Wave Energy

The potential for wave energy is charted by NREL and provided through its Atlas. The Atlas was used to obtain the map below.

Figure 4-5: NREL’s Wave Energy Potential

4-7 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

As shown in Figure 4-5, the annual wave energy potential in the Long Island Sound is not mapped by NREL, but the eastern end of Long Island indicates an area of some of the lowest potential wave energy. It is assumed that the wave energy in the Long Island Sound is less than at the east end of Long Island, hence there is little to no potential for the installation of a tidal energy system at the Northport station.

Ocean Thermal

The potential for ocean thermal energy is charted by the NREL and provided through its Atlas. The Atlas was used to obtain the map below.

Figure 4-6: NREL’s Ocean Thermal Energy Potential

Ocean thermal systems work best in areas with a temperature difference of around 20oC between surface and deep water. As shown in Figure 4-6, NREL does not chart the temperature difference in the New York area. Note, though, that the temperature difference as far south as Delaware shows only a 14-15oC differential. It can be presumed that the area around the Long Island sound is significantly less. Therefore, there is little potential for the installation of an ocean thermal energy system at the Northport facility.

Fuel Cells

Fuel cells are included in the CLCPA so long as they use a non-fossil fuel, so potential sources are limited to fuels such as hydrogen or . The Northport site, though, does not have natural storage available to support a large hydrogen fuel cell installation, and a reliable source of that would be needed to support such a facility is

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not currently available in the area. Further, even if fuel could be sourced in the future, the site could likely support the installation of only up to approximately 50 MW of fuel cells given their current footprint.

Offshore Wind

While the Long Island Sound is not optimal for offshore wind, the Northport Station is situated such that it could serve as the interconnect point for offshore wind. The approximate 75 acres of usable area on the site could support the necessary converter station and substation expansion to interconnect a large offshore wind farm. Depending on the infrastructure upgrades required, there may also be space for simple cycle gas turbines to back up some portion of the offshore wind capacity.

Summary

Ten (10) renewable technologies were examined to determine the feasibility of their potential deployment at Northport. Exclusive of potentially interconnecting offshore wind at Northport, no technology was deemed practical largely due to the relatively restrictive site size and/or lack of appropriate natural conditions.

4.2 SCENARIOS

The Study developed six (6) alternative repowering scenarios, including Grid’s proposal (Scenario 3). In addition to the six alternative scenarios, a Reference Case, reflecting a long-term resource portfolio that included operating the Northport units ‘as-is’ (i.e., no repowering occurs) was developed. The results of each alternative were compared against those of the Reference Case to determine the relative effects of its implementation. Chapter 6, Repowering Provisions and Economic Viability, presents the results of those comparisons.

The inability to introduce sufficient renewable energy resources at Northport to replace the existing plant capacity affected the Study in that it limited the reasonably applicable technologies to conventional generation and batteries. Interconnecting offshore wind at Northport and upgrading the Northport-Norfolk Cable (NNC) intertie also were considered although, technically, use of these technologies does not repower the Northport units so much as replace a portion of existing capacity with offsite resources.

There were five (5) generating technologies used in the repowering analyses, each technology applicable to one or more scenarios (except for one scenario that represents the retirement of a single steam unit with no assumed replacement capacity). The technologies considered were:

4-9 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

• Combined Cycle (CC) – 340 MW: A ‘1x1x1’ CC unit consisting of one GE 7F.05 combustion turbine generator with one heat recovery steam generator and one steam turbine generator with an air-cooled condenser.

• Simple Cycle (SC) – 230 MW: A single GE 7FA.05 combustion turbine.

• Battery Energy Storage System (BESS) – 50 MW: A 4-hour lithium-ion battery and rack system including, among other features, comprehensive site monitoring and control, and an advanced battery management system.

• Offshore Wind (OSW) – 800 MW:13 An offshore wind facility injecting into Northport.

• Northport-Norwalk Cable (NNC) Upgrade – 229 MW: Upgrade NNC import/export from +/-200 to +/-429 MW for an increase of 229 MW.

The performance attributes of the CC, SC and batteries are shown in Appendix C. Both the CC and SC technologies have high thermal efficiencies and low emissions rates as befits the latest advanced combustion technology. The CC plant would use a closed loop cooling system and the total capacity of any scenario would not exceed the Northport substation exit capabilities. The proposed combustion turbines would be designed for operation from approximately 40% minimum load to 100% of nameplate rating. While there are no significant natural gas system upgrades required, a natural gas metering station and equipment would need to be installed. A 30-day interruptible natural gas supply was assumed.

In most scenarios it was necessary to stage construction and arrange new power blocks such that the existing units could continue to operate through the construction of the new power block that would replace it. Once decommissioned the existing units could be scheduled for demolition to make room for additional expansion phases. This sequencing, in some cases, caused a significantly extended construction time frame to completely deploy the technologies comprising the scenario.

The technologies and resource sizes comprising each scenario are shown below in Table 4-1.

13 800 MW represents nameplate capacity; the Unforced Capacity (UCAP) value was assumed to be 400 MW, i.e., 50 percent of nameplate.

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Table 4-1: Repowering Scenarios: Capacity Retirements/Additions

Scenario Unit Type/Status Unit Size 1 2 3 4 5 6

NP 1 (375 MW) Y Y Y Y Y Y

NP 2 (375 MW) --- Y Y Y Y --- NP Units to be Retired NP 3 (375 MW) --- Y Y Y Y ---

NP 4 (375 MW) --- Y Y Y Y ---

1,125 Net Existing Capacity 1,125 MW 0 MW 0 MW 0 MW 0 MW MW

New CC 340 MW 1 ea. 2 ea. 2 ea. 1 ea. 2 ea. ---

New SC 230 MW --- 4 ea. 3 ea. 3 ea. 2 ea. ---

New BESS 50 MW 1 ea. --- 3 ea. 3 ea. 3 ea. ---

New OSW 800 MW* ------1 ea. ------

NNC Cable 229 MW ------1 ea. --- Upgrade

Added New Capacity 390 MW 1,600 MW 1,520 MW 1,580 MW** 1,290 MW*** 0 MW

1,125 New Northport Plant Capacity 1,515 MW 1,600 MW 1,520 MW 1,580 MW** 1,290 MW*** MW

COD Range of New Capacity 2025 - 2026 2026 - 2032 2025 - 2034 2025 - 2034 2025 - 2034 ---

* Nameplate capacity; UCAP capacity is assumed to be ~400 MW ** Assumed UCAP capacity for offshore wind *** NNC cable upgrade does not count as UCAP capacity

Note that for each Scenario the units to be retired are indicated by a “Y” in the table. (The absence of a “Y” indicates that the unit is not retired.) The “Net Existing Capacity” row is the total capacity associated with the existing units post retirement(s). “Added New Capacity” represents the total new capacity added in each Scenario and is determined by summing the amount of capacity associated with the specific type and amount of new capacity in a Scenario. “New Northport Plant Capacity” is the sum of the “Net Existing Capacity” and “New Northport Plant Capacity”.

4-11 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

There are a few notable aspects of the Scenarios. First is the extended range of time for construction of the full complement of technologies which, for 4 of the 6 options, is between 12 and 14 years (starting from 2020). This extended period is due to limited site acreage and the consequent required staging of construction of the replacement capacity and the demolition activities associated with the existing capacity. This extended time frame has a significant impact on the time available (it is reduced) for Grid to recover project costs under the assumption that natural gas fired generation cannot be part of the State’s resource supply mix by 2040 per the CLCPA. The shortened period to recover costs translates to increased annual revenue requirements up to 2040. Second, offshore wind is the only renewable technology that is any way practical at Northport (technically, offshore wind is not actually at Northport, rather the energy produced is injected into the Northport substation), again due to site constraints. Finally, for Scenarios 2 through 5, the commercial operation dates of the final elements of each scenario extend into the early 2030’s which, depending on progress achieved in reaching CLCPA goals, could affect the long-term economics of those scenarios.

Regarding the extended time required for construction associated with most Scenarios, Grid’s proposal, Scenario 3, provided a useful template for understanding in more detail some of the non-construction related activities that drive the schedule. Preliminarily, it is anticipated that execution of Grid’s proposal would occur in three phases. As shown in Appendix D, each phase contains activities related to Article 10 permitting, demolition of fuel tanks and/or demolition of existing units, along with related construction work. In combination, these tasks, sequenced both inter and intra-phase, extend the time required to fully bring the new capacity on-line. Other scenarios would be similarly phased, as necessary, and show comparably long construction/demolition periods. Figure 4-7, below, presents timelines for each scenario and depicts when the major capacity additions and retirements are scheduled to take place.

Figure 4-7: Repowering Scenarios’ Timelines: Capacity Retirements/ Additions

4-12 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

4-13 Repowering Technology Evaluation & Feasibility Repowering Scenarios Study

* Nameplate capacity: UCAP capacity is assumed to be 400 MW **NNC cable upgrade does not count as UCAP capacity.

In sum, while the scenarios are robust, they are designed to reflect the realities of what the site can actually accommodate in terms of resource type and capacity. Unfortunately, that does not allow for the inclusion of on- site renewable resources; what is feasible (i.e., conventional generation and storage) requires an extended time to design, permit, and construct, and new conventional generation is subject to early shutdown (i.e., by 2040) pursuant to the CLCPA mandate.

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Repowering 5-1 Engineering & Environmental Feasibility Analysis Study

5. ENGINEERING & ENVIRONMENTAL ANALYSIS

This chapter assesses the engineering and environmental elements of Grid’s proposal to repower Northport (i.e., Scenario 3). It includes a description and details of the major plant components, operating performance, fuel supply, delivery, and storage, and transmission system requirements. This chapter also identifies the necessary permits and licenses required to build and operate the repowered plant, and the required supporting studies. Finally, the chapter includes a discussion on project implementation issues, such as constructability and the project schedule.

5.1 ENGINEERING CONSIDERATIONS

Proposed Repowering Option

The proposed Northport repowering project (i.e., Scenario 3, Grid’s proposal introduced in Chapter 4) proposes that the existing steam Units 1 - 4 (1,500 MW total) are retired, demolished, and replaced with the installation of two 340 MW 1x1 GE 7F.05 gas-fired combined cycle units (CC), three 230 MW GE 7F.05 gas fired simple cycle units (SC), and three 50 MW lithium ion battery energy storage systems (BESS). The proposal assumes that the existing 16 MW gas-fired combustion turbine remains in place. Table 5-1 provides a summary of the existing units and major components at Northport and how they would be dispositioned under Grid’s proposal.

Table 5-1: Disposition/Addition of Major Plant Assets: Scenario 3

Total Units & Total Repowering Description & Comments Current Disposition Components Output Output

Four (4) 375 MW steam units Retire & Units 1, 2, 3 and with vintages ranging from 1967 1,500 MW remove all four 0 MW 4 to 1977. units

GE Frame 5 gas turbine GT1 16 MW Remain 16 MW commissioned in 1967.

1 unit = 340 MW (1 SC CT, 1 Combined Cycle heat recovery steam generator 0 2 new units 680 MW (CC) & 1 steam turbine)

Simple Cycle 230 MW CT 0 3 new units 690 MW (SC)

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Total Units & Total Repowering Description & Comments Current Disposition Components Output Output

Battery Storage 3 new 50 MW lithium ion battery 0 150 MW (BESS) batteries

Plant Output, Current & 1,516 MW 1,536 MW* Repowered

* Total Repowering Output includes the existing 16 MW GT1 that will remain in service.

The combined cycle units would operate on natural gas and have ultra-low sulfur distillate (ULSD) fuel backup with an onsite ten-day storage capability. They would have advanced Dry Low nitrogen oxide (NOx) combustors for natural gas firing and water injection for NOx control on distillate (ULSD) fuel. A selective catalytic reduction system (SCR) and any other necessary emission controls would be included in the design. Additional specific design parameters include combustion turbine evaporative cooling, 100% steam bypass to the air-cooled condenser on the combined cycle units, auxiliary fin cooling, and key equipment redundancy to achieve high availability.

The final detailed design of the repowered plant would likely change from the high-level description provided herein due to the typical engineering progression as the repowering project moves from conceptual, through preliminary and subsequent detailed design phases. These changes are an expected part of any design process and would not materially impact the overall results of this Study.

Repowered Unit Operating Performance

Conceptual level performance data for both fuel types (natural gas and ULSD) and at various load conditions for the repowered plant (i.e., the proposed CC and ST units) based on Scenario 3 is provided in Appendix C, the Northport Repowering Attributes Summary. The matrix includes gross and net unit performance data for three temperatures (92F, 59F and 25F) for natural gas and distillate fuel (ULSD). The matrix also includes a summary showing emission rates (NOx, SO2, CO, CO2, PM, and NH3). Also shown in Appendix C are the performance attributes for the 50 MW battery storage unit.

Fuel Supply, Delivery, and Storage

Natural gas to fire the new units would be supplied by means of the existing Iroquois pipeline with separate compression, regulation, and metering for each unit. Ultra-low sulfur diesel (ULSD) liquid fuel would be

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delivered by barge to the existing unloading facilities at the site and stored in two new fuel oil storage tanks of 10,000,000 gallons each. This would provide 100% capacity storage for ten days of full load oil firing on all new combustion turbine generators planned for the repowered site. The new tanks would be erected in the area of the existing #2 and #3 fuel oil tanks. The existing fuel oil tanks would be remediated and removed to make room for the new tanks.

5.2 TRANSMISSION SYSTEM

Grid’s proposed Northport repowering project would approximate the overall capacity of the existing site. Since the overall site capacity would be increased but only by a small amount (approximately 20 MW), it is anticipated that the need for potential electrical system upgrades would be minimal, if any. To the extent that any individual phase of construction would result in a total steam plant capacity (i.e., remaining plus new) greater than 1,500 MW, given the mix of technologies and configurations that would be available for use upon completion of a construction phase, it was envisioned that through a combination of derating the existing units and the intermittent use of the BESS and/or simple cycle units that the export capacity would be balanced to limit total exports, if necessary. Of particular consideration would be the Phase 2 construction that when combined with the Phase 1 capacity, would exceed the total installed capacity of the existing Units 1 & 2. This may include, as noted, operationally derating the remaining Units 3 & 4 such that the overall plant capacity remains nearly the same. Electric power from each new unit would be stepped up to 138 kV and consolidated in a collector bus for each phase, such that there is a single interconnect to the corresponding location in the existing substation.

The proposed new facility configuration is not intended to exceed by any appreciable amount the current substation’s exit capability. Accordingly, there are no significant changes or issues related to the existing substation structures, systems, and components or overall electrical interconnection.

5.3 ENVIRONMENTAL CONSIDERATIONS

Project Licensing & Permitting

The project would be subject to licensing and permitting under both, the New York State Department of Public Service (NYSDPS) and the New York State Department of Environmental Conservation (NYSDEC) regulations. The project would be considered a ‘major electric generating facility’ and subject to Article 10 of the New York State Public Service Law. Article 10 requires that the New York State Board on Electric Generation Siting and the Environment issue a Certificate of Environmental Compatibility and Public Need authorizing the construction

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and operation of major electric generating facilities following a detailed evaluation process. The project, though, would be considered a ‘repowering’ of an existing facility and therefore eligible for an accelerated review, but would still require air and water permits issued by the DEC. The two proceedings would be held jointly.

Article 10 proceedings roll up virtually all State and Local licensing and permitting requirements into a single process under a Siting Board. The process and application requirements are highly prescriptive, calling for forty- one (41) separate topics (see the list in Section 5.3.3) – from land use and air emissions to impacts of electric systems and telecommunications – that need to be covered in the application. For purposes of this study, each project phase (1A, 1B, etc.) was considered to be a separate licensing event estimated to take approximately 24 months, equating to six (6) separate Article 10 proceedings. However, a single proceeding for each phase might be possible at the time the selection is made.

The process begins with the development of a Public Involvement Program (PIP) designed to foster open communication with regulators, the public and other stakeholders. The applicant also issues a Preliminary Scoping Statement detailing the project scope, potential benefits, and impacts. The Scoping Statement undergoes a public comment period where municipalities and other stakeholders can provide comments. A Hearing Examiner then identifies formal intervenors who would be eligible to receive funding to evaluate the project. Prior to developing the formal application, the applicant, regulators and other interested parties would agree on stipulations intended to reach agreement on the type and extent of studies on environmental and community impacts that would be analyzed and reported in the application.

The application’s studies are comprehensive (see Section 5.3.3). Once the application is submitted and deemed complete the project would be evaluated based on the results of the studies. Intervenors would have the opportunity for funding and would be able to participate in the process. Any hearings would take place during this period. The NYSDEC permitting process for federally designated permits and other approvals would follow the Uniform Procedures Act, Article 70 of the Environmental Conservation Law (ECL).

A successful proceeding results in the issuance of a “Certificate of Environmental Compatibility and Public Need” by the Siting Board authorizing the construction and operation of the facility, as well as the issuance of the necessary air, water, and waste permits by the NYSDEC.

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Required Permits

The following table provides a summary of anticipated environmental permits, approvals, and agency consultations required for the repowering.

Table 5-2: List of Permits and Approvals

Agency Department Permit/Approval Agency Action

New York State Certificate of Board on Electric Environmental Required for commencement of State Generation Siting Compatibility and Public construction activities. and the Need Environment

Required for structures or work in navigable waters within or under Section 10 of the Rivers US Army Corps of navigable waters of the US (i.e., and Harbors Act of 1899/ Federal Engineers existing discharge canal). Level of Section 404 Clean Water (USACE) permitting (IP or NWP) will be based Act on impacts resulting from specific construction activities.

Required pursuant to FAA Regulations, Part 77- Objects Federal Aviation Affecting Navigable Airspace for Determination of No Federal Administration construction cranes or other elevated Hazard to Air Navigation (FAA) structures exceeding 200 feet or to be used within proximity to an airport or heliport.

Provides a determination of whether Federally regulated species or their Section 7: Threatened U.S. Fish and habitats are potentially present Federal and Endangered Species Wildlife Service onsite. “Determination of No Effect” Review and Consultation required to support issuance of USACE permits.

Required in support of any federal National Oceanic NOAA Fisheries (formerly permit approval to confirm that there and Atmospheric known as the National are no significant adverse impacts Federal Administration Marine Fisheries Service) from the proposed construction (NOAA) Consultation and/or operations to marine resources.

Required in support of issuance of Coastal Zone NYSDEC and USACE permits and NYS Department State Consistency approvals to ensure consistency with of State Determination designated uses of the coastal zone and applicable coastal zone policies.

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Agency Department Permit/Approval Agency Action

Required for construction that will result in a disturbance of greater than SPDES Permit one acre or the discharge of treated Modification for State NYSDEC dewatering effluents. Notification is Construction and also required for the termination of Dewatering Activities permitted process wastewater or stormwater discharges.

Article 15 - Use and Required for all work below mean State NYSDEC Protection of Waters high water line on protected streams.

Required for any work within coastal State NYSDEC Tidal Wetlands Permit wetlands and their associated buffer.

In accordance with Section 401 of the Clean Water Act, applicants for a NYSDEC or Federal license or permit for activities New York State that may result in a discharge into Water Quality waters of the United States must State Board on Electric Generation Siting Certification obtain a water quality certification and the from the state agency charged with Environment water control indicating that the proposed activity will not violate NY State water quality standards.

Consultation letter must be sent to the New York Natural Heritage Program (NYNHP), to determine if Threatened and the project will impact any protected State NYSDEC Endangered Species plant or animal species habitat. Inventory Review “Determination of No Effect” required to support issuance of NYSDEC permits.

From NYSDEC DER-11 - Procedures Major Oil Storage Facility State NYSDEC for Licensing Onshore Major Oil Permit Storage Facilities, APPENDIX B.

New York State Section 106 Cultural and Provides a determination of whether Office of Parks, Historic Resources cultural and/or historic resources are Recreation and State Review and Consultation potentially present on site. Required Historic – “Determination of No for issuance of state and federal Preservation Effect” permits. (OPRHP)

Submission to NYSDEC as required PSD Part 231/Part 201 State NYSDEC by the Clean Air Act and under NY Air Permit State law and regulation.

All stationary storage tanks at a Registration of Storage State NYSDEC facility must be registered with the Tanks Department per Part 596 regulations

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Agency Department Permit/Approval Agency Action

Chemical bulk storage notice Part 598: Notice of State NYSDEC requirement for the closeout of the Closure acid tank.

Note: Any required county and municipal approvals will be determined during Article 10 process.

Permitting Studies

As noted, the Article 10 Certificate process is very comprehensive and requires the preparation of numerous studies to assess any potential impacts resulting from a proposed project, including studies on air emissions and water. The application is functionally divided into 41 exhibits that must adequately address the following specific topics:

1: General Requirements 22: Terrestrial Ecology and Wetlands 2: Overview and Public Involvement 23: and Aquatic Ecology 3: Location of Facilities 24: Visual Impacts 4: Land Use 25: Effect on Transportation 5: Electric System Effects 26: Effect on Communications 6: Facilities 27: Socioeconomic Effects 7: Natural Gas Power Facilities 28: Environmental Justice 8: Electric System Production Modeling 29: Site Restoration and Decommissioning 9: Alternatives 30: Nuclear Facilities 10: Consistency with Energy Planning Objectives 31: Local Laws and Ordinances 11: Preliminary Design Drawings 32: State Laws and Regulations 12: Construction 33: Other Applications and Filings 13: Real Property 34: Electric Interconnection 14: Cost of Facilities 35: Electric and Magnetic Fields 15: Public Health and Safety 36: Gas Interconnection 16: Pollution Control Facilities 37: Back-Up Fuel 17: Air Emissions 38: Water Interconnection 18: Safety and Security 39: Wastewater Interconnection 19: Noise and Vibration 40: Telecommunications Interconnection 20: Cultural Resources 41: Applications to Modify or Build Adjacent 21: Geology, Seismology and Soils

The project also requires air and water permits issued by the NYSDEC. This would include the preparation of an application and supporting studies for a Part 201/Part 231 Prevention of Significant Deterioration (PSD) Permit. Part 201 requires existing and new sources to evaluate minor or major source status and evaluate and certify

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compliance with all applicable requirements. State Pollutant Discharge Elimination System (SPDES) Permits for Construction Stormwater and Industrial Discharge would also be required.

Air Emissions and Water Characteristics

Northport currently complies with all existing emissions-related permits. The proposed repowered plant, though, offers fuel and emissions benefits relative to the existing facility. Environmentally, the repowered units lower CO2 emission rates (lbs/MWh) by approximately 35% and NOx emission rates by 90% and would displace emissions from other plants. Repowering also will utilize an air-cooled condenser (ACC), thereby eliminating the existing once-through cooling system.

Of note, the proposed plant would have greater total emissions than the existing facility because of its expected higher capacity factor, i.e., its rate of emissions would be lower, but because it is more fuel efficient, it would operate more and produce more energy (i.e., megawatt-hours, or MWh); hence, total emissions from the site would be higher. So, paradoxically for those living in proximity to the plant, while a repowered unit would be more environmentally friendly from an emissions perspective on a unit basis (i.e., lbs of emissions per unit of fuel input) than the existing facility, it would produce greater total emissions. These higher emissions at the Northport site, though, would be offset by reduced emissions at other locations or by reductions in purchased power in the various energy markets. System wide emission benefits, however, can also be obtained in numerous alternate ways that do not require repowering Northport.

Environmental Benefits of New Units

A repowering of Northport would essentially replace the existing combined generating capacity of the four existing steam units with cleaner burning, state-of-the-art gas turbine technology and batteries. The benefits of repowering include:

• The replacement of older power generation with start-of-the-art combustion turbine technology in a combined and simple cycle configuration that achieves a very high fuel efficiency resulting in less fuel usage per unit of generation.

• The reduction in the rate of air emissions per MWh of energy produced through use of advanced emissions control technology and natural gas as a primary fuel.

• Eliminates the use of a ‘once-through’ cooling system at the existing plant.

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• Avoids major upgrades to the electrical transmission system.

• Modernizes an existing generating facility with the most efficient technology – given the site’s constraints.

• Flexible operation for load following intermittent renewable energy resources.

5.4 CONSTRUCTABILITY

The layout of existing plant equipment and available site acreage presents several challenges for repowering Northport. While the area available for new construction is sufficient to complete installation of the new power blocks, it is inadequate to house all contractor laydown, craft parking, staging and contractor trailers within proximity to the new power block. Therefore, open spaces around the Northport facility would need to be utilized to the extent possible to support construction. By using these spaces to support the contractor’s construction, careful coordination for delivery of equipment/materials and coordination between the contractor and Grid’s operating staff will be required. This will also impact the contractor’s productivity. Phases 1 and 3 construction activities will also be impacted due to the limited mobility around the existing units that are bound to the east by the PSEG LI substation with overhead connections and the Northport inlet road to the west. The contractor may need to consider barge delivery and off-loading for major equipment. This may require improvements to the dock area to accept large barge deliveries.

An additional challenge is that demolition of Units 1 and 2 and construction of the Phase 3 simple cycle unit would need to take place directly adjacent to the Phase 1 and Phase 2 power blocks. These units must be available to operate throughout the course of demolition and construction. It is likely that barriers will need to be constructed to isolate and protect the units and construction activities, and such barriers and associated construction activities will have to be scheduled during non-operating periods.

It will be imperative for the contractor to develop a construction plan and schedule that sequences the installation of major equipment in a manner that avoids costly delays due to the limitations of crane access at the site. The use of off-site modular construction, particularly regarding the heat recovery steam generator (HRSG) and air-cooled condenser (ACC), is recommended and would be beneficial to both reducing the amount of on-site labor activities as well as the number of large crane picks.

Based on an earlier assessment, there is likely a need to limit the impact of noise on the surrounding community. To address noise concerns, enhanced sound attenuating features will likely be required from original equipment

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manufacturer (OEM) suppliers for the major noise generating equipment. This includes items such as enclosures for the unit’s Boiler Feed Pumps, sound isolating panels atop the HRSG and elsewhere where engineering judgement determined a need, low noise fans and sound attenuating at selected areas of the ACC, and air inlet and stack silencers. Allowances in the project cost were made for noise mitigation based upon best engineering judgment should future sound modeling surveys determine their need.

Demolition

Demolition will include decommissioning and demolition of all four steam units, fuel oil tanks, and the administration building. The small 16 MW simple cycle combustion turbine unit on the site will remain. Appropriate demolition means and methods will consider impacts to the operating units, the environment, and the community.

Equipment Delivery

Access to the site for the delivery of equipment is adequate. The site can be accessed by means of two roads. The primary access is off Fort Solonga (Route 25A) onto Waterside Avenue. Waterside Avenue is a narrow, two-way road with residences on both sides, narrowing as it approaches the Northport site. A second means of entry to the site is through the Northport boat ramp area. A pathway east of the Northport soccer park leads directly into the Tank Farm area of the existing site. Delivery is also possible by barge into the Northport inlet road and offloaded directly into the construction areas for the Phases 1 and 3 combined cycle power blocks. It is likely that larger equipment and construction equipment may need to be delivered via barge due to the limited width and height along the east and west sides of the existing units.

5.5 STORM PROTECTION

Northport is, for the most part, outside the 0.2% (1 in 500 year) annual chance floodplain. Superstorm Sandy demonstrated the ability of the current plant to handle heavy storm conditions. The main plant was generally unaffected by that storm, both due to its design features as well as compensatory operational measures, such as closing and sealing external doors, placing protective sandbags around motor control centers and other sensitive equipment, etc. Therefore, extraordinary grade modifications or storm hardening provisions were not addressed as part of the study.

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5.6 PROJECT SCHEDULE

A summary level project phasing schedule, shown in Appendix D, was developed for the proposed Northport repowering (i.e., Scenario 3) to indicate the required construction and demolition timing for each phase. The schedule, as previously noted, is comprised of three phases and is laid out over a 13.5-year schedule.

Phase 1 provides for a 2-year period to complete the Article 10 process for Phase 1. Following receipt of required permits, existing fuel oil tanks 2 & 3 would be demolished to create laydown space to support construction. The execution phase of the construction is scheduled for 3 years starting with the completion of the Article 10 and air permitting processes. The construction of the battery energy storage system (BESS) would commence approximately one (1) year after the start of the Combined Cycle (CC) and be completed such that it can be commissioned along with the CC plant.

The Phase 2 Article 10 and air permitting commences in Year 2, with a 2-year time frame to complete. Similar to Phase 1, the permitting process is followed by a 3-year execution phase for the Phase 2 Simple Cycle (SC) units. Total construction time will likely require less than 3 years to complete; however, additional time was allotted to account for existing facilities that must be relocated or demolished prior to starting construction of the SC units. Following the completion of Phase 2 construction, existing Units 1 & 2 can be demolished, which is anticipated to require 2 years to complete.

Due to this schedule constraint under Phase 2, the Phase 3 Article 10 and air permitting processes for the new CC and SC units does not commence until after the completion of Phase 2 construction and coincides with the Units 1 and 2 demolition efforts. The Phase 3 CC and SC construction commences in Year 9 following the demolition of Units 1 and 2 and related Phase 3 permitting. Construction execution is scheduled for a 3-year period. The Phase 3 BESS construction, however, cannot begin until the existing fuel oil tanks supporting Unit 3 and Unit 4 operation are demolished, which cannot take place until after these units are officially shuttered. Therefore, Phase 3’s Article 10 process for the BESS is scheduled to begin in Year 11, with BESS construction complete in the middle of Year 14.

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6-1 Repowering Repowerig Provisions and Feasibility Economic Viability Study

6. REPOWERING PROVISIONS AND ECONOMIC VIABILITY

The purpose of this chapter of the report is twofold: • To set forth and address the Ramp Down and Repowering provisions, specifically Articles 10 and 11 of the PSA; and • To present and discuss the results of the economic analyses associated with each Scenario relative to the Reference Case, specifically the increase in total costs attributable to repowering and the associated impacts on the cost of electricity to customers.

6.1 RAMP DOWN AND REPOWERING PROVISIONS

Under Article 10 of the PSA, LIPA has the contractual right to reduce (Ramp Down) all or any portion of the Northport generating unit capacity at the site14 that it is obligated to purchase from Grid. The exercise of the Ramp Down provision is subject to the following conditions: • Prior written notice: LIPA must provide 2-years notice for steam units and a 1-year notice for all other units prior to the Ramp Down Effective Date.15 • Payment: LIPA is obligated to make a Ramp Down payment upon the effective date of the Ramp Down, which payment is equal to:

o The net book value of the ramped down unit(s) as of the Ramp Down Effective Date, less o Any applicable discounts per Appendix G of the PSA, plus o For the steam units, an amount equal to 18 months of operating and maintenance expenses (both allocated and direct) and 12 months of operating and maintenance expenses in the case of non-steam units, less 16 o The notional account (Tracking Account) up to the lesser of the Ramp Down payment or the amount in the Tracking Account. • Retirement Eligible: The unit(s) to be ramped down are found to be able to be retired from a reliability perspective.

14 Northport Steam Units 1, 2, 3 and 4, and the 16 MW simple cycle gas turbine. 15 The earliest Ramp Down Effective Date of any or all of the Northport steam generating units is May 1, 2021. 16 The amount in the Tracking Account is equal to the Net Book Value of Northport 1 as of May 31, 2013.

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• Property Taxes: For a steam unit, LIPA is responsible for reimbursement of the property taxes paid by Grid for the remainder of the Calendar Year in which the Ramp Down Effective Date occurs and for the three (3) succeeding Calendar Years thereafter or until the end of the term of the PSA, whichever occurs first.17

Upon the effective date of the Ramp Down, LIPA has no further right or obligation to purchase or pay for the capacity and associated costs of the ramped down unit(s) and the capacity and other charges under the PSA will be reduced accordingly. Grid, upon receipt of the Ramp Down notice, must, within 90 days, advise LIPA whether Grid will either continue to operate the ramped down unit(s) or shut down and mothball or demolish the unit(s).

Article 11 of the PSA provides LIPA an option to direct Grid to, among other things, repower any or all of the Northport units. Repowering is defined as: “. . . replacing part or all of each generating unit . . . with new generating equipment or entire units.” In the event this option is exercised, LIPA is obligated to make certain one-time payments (Repowering Payment) associated with the unit(s) that is being taken out of service for purposes of the repowering. Such payments include:

• The net book value of the unit that is being repowered as of the date the unit is taken out of service;

• Less the applicable discount as provided in Appendix G (of the PSA);

• Less the notional account (Tracking Account) up to the lesser of the Repowering Payment or the amount in the Tracking Account.

LIPA is also responsible for the costs associated with demolition and site remediation. Such cost, including a return, would be recovered over the term of the new unit’s PPA or, at LIPA’s option, in one lump sum.

LIPA’s payments under the PSA would be reduced to reflect the Northport unit(s) removed from service due to the repowering. The reduction in the payments under the PSA would include costs associated with return and depreciation, and direct and indirect O&M. Additionally, per the provisions of Article 11, for each repowered unit, LIPA and Grid would enter into a mutually acceptable Purchase Power Agreement (PPA) under which LIPA would agree to purchase the repowered unit’s capacity, energy, and ancillary services.

17 Assumes the unit(s) are ramped down and retired.

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For purposes of this analysis, it was assumed that LIPA would exercise its rights under the Repowering Option and direct Grid to repower the Northport facility. LIPA and Grid would enter into a mutually acceptable long- term purchase power tolling18 agreement for each of the repowered units with Grid retaining ownership of the site. It was also assumed that there would be no change in the level of annual property taxes, i.e. the annual property taxes associated with the repowered units would be the same as the amounts that are projected to be paid in the absence of repowering. LIPA has certain rights under both the PSA and, separately, under Schedule F of the Merger Agreement, to purchase the ramped down generating facility, including the related site and all Regulatory Rights. These purchase rights are addressed in detail in Section 6.3, below.

6.2 ECONOMIC ANALYSIS

The costs and benefits of repowering Northport are reflected in the results of the Production Cost modeling19 and Financial Model runs. The Financial Model is a comprehensive representation of LIPA’s annual revenue requirement based upon LIPA’s financial objectives. Essentially, the Financial Model captures all projected annual expenses and revenue and produces a pro forma financial statement by year for each year of the Study Period, 2020 - 2040.

Modeling Considerations

As noted, elements of the Financial Model include all costs expected to be incurred each year, including, but not limited to, those associated with the following: • Total fuel and purchased power costs (Production Cost Model) • Electric transmission and distribution capital expenditures, including those, if any, required due to repowering. (There were no repowering related electric transmission and distribution expenditures assumed in the Study.) • Payments LIPA makes for Power Purchase Agreements (PPA), including the PSA • Operating Services Agreement (OSA) charges • Property taxes (PILOTs) • Debt service

18 LIPA would be responsible for the procurement and delivery of gas and oil for the combined cycle and simple cycle units; and for electricity for the batteries. 19 The key tools used to assess production cost, emissions and capacity impacts are described in Appendix E - Production Cost Methodology, and Appendix F - Market Forecasting Methodology.

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• Satisfaction of LIPA’s coverage ratio targets • LIPA’s 18% ownership of Nine Mile Point 2

As further described below, there are two main categories of costs and impacts associated with a ramp down or repowering of a generating unit:

• Production costs, e.g., fuel and variable O&M

• Fixed cost, e.g., the reduction in the PSA Capacity Charge and the PPA cost of the repowered unit

Production Costs and Financial Model runs were made for Grid’s Northport repowering proposal (Scenario 3)20, which include the phased installation of two 340 MW CC units, three 230 MW SC units, and three 50 MW BESS units. Grid’s proposal assumes that the design, permitting, and construction of the new units would occur on the Northport site over a period of approximately fourteen years. Specifically, Grid’s proposal targeted replacing each existing unit in a phased approach where a new unit is built in an open area of the site, its electric output tied into the substation bay of the unit it is replacing, and the existing unit then decommissioned and demolished creating space for future phases of the repowering, while the remaining existing units continued to operate. A timeline of the commercial operation dates (COD) of the “new” units and the retirement/demolition of the existing units is shown in Appendix D. In addition to analyzing Grid’s repowering proposal, Production Cost and Financial Model runs were made for the five other scenarios described in Section 4.2, Scenarios, of this report.

Economically, Grid proposed that LIPA enter into a long-term PPA for each of the repowered units, which contained the following major provisions:

• A 20-year term • A constant (flat) annual capacity payment • A Fixed O&M payment with a fixed annual escalation rate (2% for CC and SC units and 1.5% for BESS) • Variable O&M $/MWH charges • PILOT’s to be paid by LIPA • The costs associated with the demolition of the existing Northport units • LIPA would be responsible for fuel (gas and oil) procurement including delivery to the plant

20 Presented as Scenario 3 in Chapter 4, and further descripted in Chapter 5.

6-5 Repowering Repowerig Provisions and Feasibility Economic Viability Study

For illustration purposes, Table 6.1 shows the cost impact in a typical year of exercising the Repowering Option for one Northport steam unit using a similar sized gas fired combined cycle unit (Scenario 1) relative to the Reference Case.

Table 6-1: Northport Unit Repowering Cost Impact in 2030

Cost Type Cost $M

CC PPA $116 Fixed Costs PSA Capacity Charge ($45)

CC Production Costs Fuel & Purchased Power ($7) Savings

Net Cost Increase $64

As can be seen, the fixed costs associated with the CC PPA significantly exceeds the reduction in the PSA Capacity Charge. Although the repowered unit results in a reduction in system production costs (fuel and purchased power), this reduction is not nearly sufficient to offset the overall increase in fixed costs. Several factors contribute to the modest reduction in production costs, including relatively low projected gas prices and the significant addition of renewable energy (OSW) being injected into Long Island, which tends to suppress the market price of energy as well as the amount of time the CC operates at full load.

Summary of Results

The impact (cost increase or decrease) on LIPA, and correspondingly its customers, associated with Grid’s Northport repowering proposal (Scenario 3), as well as the other five (5) scenarios evaluated, was measured as the difference between two Financial Model runs covering a 20-year Study Period, 2020 – 2040.

• A common Reference Case based upon the following: the currently approved load and energy forecast; the retention of the existing on-island power supply portfolio; the implementation of various initiatives to help satisfy the goals set forth in NY State’s CLCPA; the cables (Neptune and Cross Sound Cable) remaining in-service; and, the satisfaction of local and statewide reliability obligations.21

21 The LI Locational Capacity Requirement (LCR) and the Statewide Installed Reserve Margin (IRM).

6-6 Repowering Repowerig Provisions and Feasibility Economic Viability Study

• The Reference Case ‘but for’ the assumed Scenario.

In terms of the financial and cost impacts of each Scenario, two approaches were considered. The first approach was to assume the PPA pricing as proposed by Grid for each of the repowered units, which pricing was based on a 20-year term starting from the point in time at which each new unit goes into commercial operation, even though such pricing would extend beyond the Study Period end date of 2040. The second approach was to assume that for any given scenario that the costs associated with conventional generation would be recovered on an accelerated basis, (i.e., by the beginning of 2040 when the CLCPA requires 100% carbon free emissions from electric generation) to reflect the likelihood that such projects would then be forced to retire. Table 6-2, below, provides a summary of the total increased costs customer bill impacts of each Scenario under both approaches when compared to the Refence Case. Positive numbers reflect increased costs to LIPA and its customers and negative numbers reflect decreased costs. Results for Scenario 6 are based upon a proportionate reduction (~25%) in Northport property taxes due to the ramp down and retirement of one unit at Northport. The exact value of a reduction in property taxes is uncertain. However, even assuming that there was no reduction in property taxes, LIPA’s costs would still be lower, albeit to a lesser degree, e.g., a reduction of $68 million as opposed to the $303 million shown in Table 6-2.

Table 6-2: Increased Costs thru the Study Period (2020 - 2040)

Total Incremental Costs (NPV: $millions)

Scenario

PPA Type 1 2 3 4 5 6**

20-Year $682 $1,704 $1,616 $1,220 $1,569 ($303)

Full Recovery $770 $1,982 $2,081 $1,470 $1,948 ($303) by 2040*

Total Incremental Residential Bill Costs ($)

Scenario

PPA Type 1 2 3 4 5 6**

20-Year $597 $1,565 $1,480 $1,092 $1,436 ($263)

6-7 Repowering Repowerig Provisions and Feasibility Economic Viability Study

Full Recovery $663 $1,794 $1,894 $1,301 $1,768 ($263) by 2040*

* Only for technologies using fossil fuel. ** Unit 1 retirement only. There is no associated PPA with Scenario 6. Results are based upon a reduction of approximately 25% in Northport property taxes

Both the net present value of increased costs and the increase in the total bill of an average residential customer are significant assuming a 20-year PPA for Scenarios 1 – 5, and even greater when considering full cost recovery by 2040. Scenario 6, retirement of Northport Unit 1 only (i.e., no associated PPA) shows a reduction for both total costs and in total costs for a typical residential bill.

Results for Grid Proposal (Scenario 3)

In viewing the results of Scenario 3 (i.e., Grid’s proposal) and assuming a 20-year PPA, Figure 6-1 shows an increase in LIPA’s total annual costs in each full year for the period 2026 - 2040.

Figure 6-1: Increase in Annual Costs: Scenario 3

$350,000

$300,000

$250,000

$200,000

$000 $150,000

$100,000

$50,000

$-

Figure 6-2 shows the composition of the increases depicted in Figure 6-1. Specifically, the reduction in production costs (fuel and purchased power) attributable to the more thermally efficient repowered units, along with the decrease in the PSA Annual Capacity Charge resulting from the retirement of the existing Northport units, is not sufficient to offset the higher PPA fixed costs associated with the repowered units. As measured over the first full

6-8 Repowering Repowerig Provisions and Feasibility Economic Viability Study

10 years (2026 – 2035), the total additional cost ($ nominal) to LIPA’s customers is $1.945 billion, and over the course of the Study Period (thru 2040), the total additional costs to LIPA’s customers is $3.088 billion.

Figure 6-2: Composition of Increase in Annual Costs: Scenario 3

350

300

250

200

150

($M) 100

50

0

(50)

(100) 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040

Gross Increase Production Cost Reductions Net Increase

Grid’s Northport repowering proposal (i.e., Scenario 3) results in increases in residential customers’ bills. As measured over the first full 10 years (2026 – 2035), the total additional cost ($ nominal) to an average residential customer is $985, and over the course of the Study Period (thru 2040) the total additional cost to an average residential customer is $1,480, assuming a 20-year PPA. If the total costs of each PPA were to be recovered by 2040, the increase to the average residential customer would be $1,894.

Results for Repowering or Retirement of a Single Unit (Scenarios 1 and 6)

As shown in Table 6-2, ramping down and retiring a Northport steam unit (Scenario 6) results in a net present value reduction in total costs of $303 million (assuming an approximate 25% reduction in property taxes) as compared to not ramping down a unit. Conversely, repowering a unit at Northport (Scenario 1) results in an increase in total costs of $682 million assuming a 20-year PPA and an increase of $770 million assuming the cost of the repowered unit would be recovered by 2040. As demonstrated in Figure 6-3, reliability criteria are satisfied under either scenario. In fact, there remains a considerable amount of excess on-island capacity even if a Northport unit is ramped down and retired.

6-9 Repowering Repowerig Provisions and Feasibility Economic Viability Study

Figure 6-3: Capacity Excess Under Scenarios 1 and 6*

8,000

7,000

6,000

5,000

4,000 MW

3,000

2,000

1,000

- 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 Year Available Capacity under Scenario 1 Available Capacity under Scenario 6 Capacity Requirement

LI Locational Capacity Excess (MW)

Year 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040

Scenario 1,544 1,706 2,123 2,098 1,756 1,719 2,079 2,037 1,981 2,132 2,058 1,985 1,914 1,833 1,751 1

Scenario 1,154 1,316 1,733 1,708 1,366 1,329 1,689 1,647 1,591 1,742 1,668 1,595 1,524 1,443 1,361 6

*For the purpose of the economic analysis, it was assumed that the terms and conditions of the PSA would extend through 2040.

The Northport power station has become increasingly less competitive in the energy market in recent years as manifested by a steady decline in the steam units' average capacity factor (see Figure 6-4).22 As shown, the annual capacity factor declined from 30.3% in 2010 to 22.9% in 2015 and is projected to decline to 2.9% by 2035. The station, though, is highly reliable as measured by its availability to operate, particularly during the critical summer months, June through August. In the summer periods from 2014 – 2019, the units were available to generate energy an average of over 96% of the time, significantly above a peer group average of about 88%. In summary,

22 Values for 2010 and 2015 are actuals and values for 2020 – 2035 are projected.

6-10 Repowering Repowerig Provisions and Feasibility Economic Viability Study

the existing Northport units are expected to remain useful for their ability to serve as reliable standby units, and there is no compelling reason to repower the units for heavier use.

Figure 6-4: Northport Capacity Factor Trend

35.0

30.0

25.0

20.0

15.0

10.0 Capacity Factor (%) Factor Capacity 5.0

0.0 2010 2015 2020 2025 2030 2035 Actual Projected

As noted previously, capacity factor is a measure of a generating unit’s energy output and, therefore total emissions, since emissions are directly related to energy output. Consequently, emissions at Northport have declined significantly and will continue to decline over time due to changing system conditions brought on by, among other factors, energy efficiency programs, the introduction of increasing levels of renewable energy, e.g. Orsted’s (formerly Deepwater Wind) offshore wind farm, and, more significantly, the implementation of various initiatives designed to achieve the mandates set forth in the CLCPA.

6.3 SITE ACQUISITION OPTIONS

LIPA has certain site acquisition rights under Article 10 of the PSA and, separately, under Schedule F, Grant of Future Rights to the Merger Agreement. The exercise of either of these site acquisition options would give LIPA the ability to select and contract with a party other than Grid to build, own and operate generating units on the acquired site. The following is a brief description of LIPA’s rights under each option.

6-11 Repowering Repowerig Provisions and Feasibility Economic Viability Study

PSA Article 10 Capacity Ramp Down

In the event LIPA choses to ramp down all or any portion of a generating facility’s capacity during the term of the PSA (ending April 30, 2028) and Grid notifies LIPA that, pursuant to Section 10.2.2, it will shut down and mothball or demolish the generating facility as of the effective date of the ramp down, LIPA has the right to purchase the generating facility including the related site.23 If LIPA exercises its purchase option under Section 10.2.2 of the PSA, or its right to purchase the site under Schedule F, as discussed below, LIPA has the right to elect to contract with a third party, or Grid, to repower or construct new generation on the site. However, regarding the repowering of the four (4) Northport steam units, if LIPA wishes to initiate a repowering within a three-year period commencing with the Ramp Down Effective Date, the procedures set forth in Article 11 of the PSA must be employed.

Schedule F – Grant of Future Rights

Under Schedule F, LIPA has the right to lease or purchase parcels of land at any of the generating facility sites of Grid for the purpose of constructing new electric generating facilities to be owned by LIPA or its designee, provided such lease or purchase does not materially interfere with either the physical operation of any generating facility or environmental compliance. In the event of interference, LIPA must provide compensation. The lease or purchase price will include the fair market value at the time of lease or purchase as determined by a jointly selected independent real estate appraiser. Of note, the Northport site is not believed to have sufficient available land to develop new generation on the site separate from the existing units.

LAST PAGE OF CHAPTER 6.

23 Per the PSA, “Generating Facility Site” means each parcel of land upon which the generating facility is situated together with land contiguous thereto owned by Grid.

Repowering 7-1 Feasibility Impact on The Community Study

7. IMPACT ON THE COMMUNITY

7.1 JOBS

The most significant impact on jobs is expected during the construction period. Grid’s three-phase Northport repowering proposal (Scenario 3), while extending over almost 14 years in total, includes approximately eight years of construction activity. The total number of construction jobs created during the construction period is estimated to be 440 jobs in Phase 1, 240 jobs in Phase 2, and 590 jobs in Phase 3. The peak construction period is expected to be in the first half of 2025 during which nearly 680 jobs would be created. Table 7-1 below provides a summary of the estimated peak number of construction jobs that would be created during each phase of the Northport repowering.

Table 7-1: Peak Construction Jobs Creation: Scenario 3

Repowering Construction Peak Number New Units In-Service Date Phase Period of Jobs

1x1 CC January 1, 2026 Phase I 2023 - 2025 440 1 BESS May 1, 2025

2x0 SC January 1, 2027 Phase 2 2024 - 2026 240 1 BESS May 1, 2025

1x1 CC January 1, 2032

2029 – 2031, and Phase 3 1x0 SC January 1, 2032 590 2033 - 2034

1 BESS May 1, 2034

Total 8 Years 1,270

In addition, it is estimated that there would be approximately 50 – 60 full time positions created related to operations and maintenance once the new units were placed in-service. Finally, there would also be positive direct and indirect effects on the local economy during the construction period, but those effects have not been studied.

7.2 TAXES

A significant economic disincentive to repowering Northport is the level of taxes that the community of Huntington levies against the plant. LIPA has identified the significant, disproportionate, and burdensome effect

Repowering 7-2 Feasibility Impact on The Community Study

of taxes on LIPA’s customers. Notably, taxes paid by LIPA, in all their forms (PILOTs, fees, etc.), totaled over $680 million in 2019, representing approximately 15 percent of a customer’s monthly bill, or 3 times the national average. LIPA’s tax payments in 2020 for four major power stations, owned by Grid, will be $184 million: $86.1 million a year for Northport, $43.2 million for the Barrett plant, $30.8 million for Port Jefferson and $23.9 million for the Glenwood Landing property, which no longer houses a steam plant. It is interesting to note that taxes paid on those four facilities in 1999 totaled slightly over $116 million. So, in 21 years, taxes on those plants have risen almost 59 percent while use of the plants continues to decline. Not surprisingly, LIPA has been seeking a tax reduction since 2010.

LIPA’s efforts to reduce the property taxes at the plants have begun to bear fruit. In December 2018, LIPA and the Town of Brookhaven and the Village of Port Jefferson reached agreements on deals that will, among other provisions, reduce LIPA's tax bill for the Port Jefferson power station by approximately 50 percent over a phase- down period starting in 2019. The move would reduce the $32.6 million LIPA paid in annual taxes in 2018 for the plant to just over $16.8 million by 2026. LIPA also reached a tentative agreement with Nassau County in November 2019 to reduce taxes on the Barrett and Glenwood plants under terms similar to those for Port Jefferson. Regarding Northport, court proceedings between LIPA and the Town of Huntington to resolve the issue have concluded and while no decision has been rendered as yet by the court, LIPA and the Town are in discussions about a potential settlement. Should no settlement be reached, a court decision is expected in 2020.

While taxes should be paid by electric customers to locales hosting power plants, the tax burden should be both equitable and reasonable. LIPA continues to strive to achieve that balance for the benefit of its customers.

LAST PAGE OF CHAPTER 7.

Repowering 8-1 Feasibility Conclusions Study

8. CONCLUSION

The Study evaluated the engineering, environmental permitting, and cost feasibility of repowering the Northport power plant. Grid’s repowering proposal (i.e., Scenario 3) is based on a multi-year, multi-phase approach that includes gas-fired combined cycle and simple cycle units, and bulk energy storage batteries. It does not include on-site renewable resources. Additional scenarios, though, included other technologies such as offshore wind and a cable upgrade.

Based on the Study’s analysis, the following conclusions were reached:

• Given the overall outlook for Long Island that shows a current surplus of installed generating capacity that is expected to grow as new, clean renewable resources are added in response to state policy and legislation, combined with load growth that is expected to decline until 2028 and then increase only gradually thereafter, there will be less room in LIPA’s supply portfolio for conventional gas-fired generation, whether it’s the current fleet of LILCO-era generating units or new repowered units. Increasingly, over time, the older conventional units will be excess to LIPA’s resource needs and strong candidates for retirement. Already LIPA has announced plans to retire in 2020 and 2021 two of the older peaking units contracted under the PSA, with more such announcements to come in the future pending the results of further planning studies.

• Grid has proposed a repowering configuration that has certain environmental benefits (i.e., lower rate of emissions) and better operational characteristics (lower heat rate and, therefore, more efficient) compared to the existing Northport plant. However, since all conventional gas-fired generation in the state is gradually being phased out by 2040 per the goals established in the CLCPA, the emissions benefits of a conventional repowering likewise would fade away by 2040.

• Grid’s repowering proposal is technically feasible, i.e., the repowered plant can be constructed and operated as proposed by Grid. This also means the repowered plant can obtain the necessary permits to construct and operate the plant based on known environmental requirements and expected changes. However, as further elaborated below, Grid’s proposal would increase costs to ratepayers and is not in ratepayers’ interests.

• The existing Northport plant can be expected to continue operating reliably through the end of the Study Period.

Repowering 8-2 Feasibility Conclusions Study

• Along with Grid’s proposal, an additional five (5) scenarios were evaluated to form a more robust understanding of the costs of repowered plant configurations. The key conclusions are as follows:

o There is no scenario, including Grid’s proposal, which includes the construction of new conventional natural gas-fired generating capacity and/or batteries, under which the reduction in production costs (fuel and purchased power) associated with the repowered plant, plus the decrease in the PSA Annual Capacity Charge resulting from the retirement of the existing Northport units, are sufficient to offset the higher PPA fixed costs associated with the repowered units. This result is consistent whether the economic analysis assumes 20-year PPAs for conventional gas-fired units, which would expire post the 2040 CLCPA mandate for 100% carbon free electricity generation, or that the costs of conventional units are fully recovered by 2040.

o Grid’s repowering proposal would result in an approximate total net present value cost to LIPA’s customers of between $1.6 billion and $2.1 billion, or about $1,500 to $1,900 (nominal dollars) per customer over the Study Period, dependent upon the type of PPA assumed.

o Scenario 6, representing retirement (not a repowering) of a steam unit, results in reduced costs of approximately $300 million24 (net present value) and retirement of a unit still allows for local and system reliability standards to be met.

LIPA has made no decision as yet regarding the retirement of additional steam plants (Northport, Barrett or Port Jefferson) beyond those (Far Rockaway and Glenwood) that were retired in 2013. However, it is likely that results of analyses conducted during 2020 will indicate additional closures, as early as 2022 – 2023. Consequently, the retirement of one or more of the steam units at Northport is more likely in the coming years than a repowering of the plant as long as the impacts on the reliability of power supply both for Long Island overall and for the local area served by the plant remain within acceptable criteria. Such a decision would be consistent with LIPA’s more recent decision to retire two gas turbine units in 2020 and 2021.

There are many variables (such as the CLCPA) under development and/or in implementation that create uncertainty regarding the optimal characteristics and configuration of a repowering that might impact the Study’s

24 This assumes a savings of approximately 25% of current property taxes. However, even assuming no change in property tax levels, it is still economic to retire at least one Northport unit.

Repowering 8-3 Feasibility Conclusions Study

conclusions. Many of these uncertainties are expected to be clarified with time. In fact, the changing market and regulatory conditions will be evaluated in detail in LIPA’s next Integrated Resource Plan (IRP), scheduled to begin in 2020. Results of the IRP will provide a roadmap for decisions regarding the deployment of new, clean energy on Long Island and the disposition of existing capacity. However, none of the repowering configurations examined in this Study - except a unit retirement - are in the best economic interests of LIPA’s customers and a repowering of Northport should be, if not abandoned, at least deferred, as there is no current economic or reliability basis for proceeding.

LAST PAGE OF CHAPTER 8.

Repowering 9-1 Feasibility Acronyms and Abbreviations Study

9. ACRONYMS AND ABBREVIATIONS

Term Definition or Clarification

Barrett The E.F. Barrett Power Station, located in the Town of Hempstead in the County of Nassau, New York

BESS Battery Energy Storage System

Bill The New York State Senate – Assembly January 15, 2015 Senate Bill 2008-B and Assembly Bill 3008-B

Board Long Island Power Authority Board of Trustees

BOP Balance of Plant: Includes Structures, Systems, and Components of a facility

CC Combined Cycle: A power generating unit composed of a combustion turbine generator, a heat recovery steam generator, and a steam turbine generator

CES Clean Energy Standard: A New York State PSC Order adopting the goal that 50% of New York’s electricity is to be generated by renewable sources by 2030. The goal has now been increased to 70% by 2030 through the CLCPA.

CF Capacity Factor

CLCPA Climate Leadership and Community Protection Act: The CLCPA was signed into law in July 2019 and establishes various clean energy goals for New York State

COD Commercial Operation Date

CT Combustion Turbine

DMNC Dependable Maximum Net Capacity

EAF Equivalent Availability Factor

EFORd Equivalent Forced Outage Rate-demand

GENCO A legal entity of National Grid USA (in the context of this report, another term for National Grid) that operates the power generation assets in accordance with a Power Supply Agreement with LIPA

Grid National Grid

Heat rate A measure of an electric power plant’s efficiency at converting fuel energy, measured in MMBtu, to electric power, measured in MWh.

LI Long Island

Repowering 9-2 Feasibility Acronyms and Abbreviations Study

Term Definition or Clarification

LILCO Long Island Lighting Company

LIPA Long Island Power Authority: a publicly owned, not-for-profit electric utility chartered to supply electric power to Long Island and the Rockaways. kW Kilowatt: a unit of power generation capacity kWh Kilowatt hour; a unit of electric energy used to measure how much electricity is generated or used.

MMBtu 1,000,000 British thermal units; a unit of energy used to measure how much energy in fuel is available to be converted to (see Heat Rate, above)

MW Megawatt: A unit of power generation capacity. A megawatt is equivalent to 1,000 kWs

MWh Megawatt hour: A unit of electric energy to used measure how much electricity is generated or used. A megawatt hour is equivalent to 1,000 kilowatt hours

National Grid National Grid USA, the investor-owned energy company that owns and operates E.F. Barrett under a Power Supply Agreement (PSA) with LIPA.

NNC Northport-Norwalk Cable: A submarine transmission cable across Long Island Sound to the Norwalk Harbor in Connecticut

Northport The Northport Power Station

NP Northport Power Station

NYSDEC New York State Department of Environmental Conservation

NYSDPS New York State Department of Public Service

NYISO The New York Independent System Operator

NYSERDA New York State Energy Research & Development

O&M Operations & Maintenance

OSW Offshore Wind

Port Jefferson Port Jefferson Power Station

PPA Power Purchase Agreement

Repowering 9-3 Feasibility Acronyms and Abbreviations Study

Term Definition or Clarification

PSA Amended and Restated Power Supply Agreement dated October 12, 2012 and effective May 29, 2013, between LIPA and National Grid.

PSC Public Service Commission

PSEG LI PSEG Long Island: a subsidiary of Public Service Enterprise Group Incorporated (PSEG) that operates LIPA’s transmission and distribution system under a 12-year contract.

REV Reforming the Energy Vision: A PSC policy framework to change the electric industry and ratemaking approach to capitalize on technology developments in conjunction with the SEP

SC Simple Cycle: A power generating unit composed of a combustion turbine

SPDES State Pollutant Discharge Elimination System

SEP State Energy Plan: intended to coordinate all State agencies’ efforts affecting energy policy to advance the REV agenda.

STG Steam Turbine Generator

UCAP Unforced Capacity

ULSD Ultra-Low Sulfur Distillate fuel

LAST PAGE OF ACRONYMS AND ABBREVIATIONS.

Repowering A-1 Feasibility Benchmarking Study

Appendix A: Benchmarking - Annual

Repowering A-2 Feasibility Benchmarking Study

Appendix A: Benchmarking - Summer

B-1 Repowering RCMT Condition Assessment Report Feasibility (Redacted) Study

Appendix B: RCMT Condition Assessment Report (Redacted)

C-1 Repowering Northport Repowering Attributes Feasibility Summary Study

Appendix C: Northport Repowering Attributes Summary

C-2 Repowering Northport Repowering Attributes Feasibility Summary Study

Northport Repowering - Phase 1 & 3 Estimated Performance

Configuration - 7F.05 1x1 CCGT

Fuel Natural gas Fuel Oil

Ambient Dry Bulb def F 15 59 92 15 59 92

Relative Humidity % 60 60 60 60 60 60

CTG Load % 100% 100% 100% 100% 100% 100%

Evap Cooler Status On/Off Off Off On Off Off On

CTG Gross Output kW 257,154 241,015 228,064 262,989 259,026 244,872

STG Gross Output kW 120,852 119,045 106,097 117,199 123,366 109,574

Plant Gross Output kW 378,006 360,060 334,161 380,108 382,392 354,446

Plant Net Output kW 368,570 350,513 324,815 371,995 373,835 346,042

Auxiliary Load kW 9,436 9,547 9,346 8,113 8,557 8,404

Plant Net Heat Rate (HHV) Btu/kWh 6541 6,560 6,833 7,010 6,960 7,247

Water Injection for NOx kpph 0 0 0 142 142 137 Control

Part Load Configuration - 7F.05 1x1 CCGT

CTG Load % 75% 75% 75% 75% 75% 75%

Evap Cooler Status On/Off Off Off Off Off Off Off

CTG Gross Output kW 181,926 172,445 162,443 185,130 187,552 174,928

STG Gross Output kW 102,702 98,917 89,502 100,732 100,631 92,852

Plant Gross Output kW 284,628 271,362 251,945 285,862 288,183 267,780

Plant Net Output kW 276,417 262,867 243,592 278,500 280,346 260,031

Auxiliary Load kW 8,211 8,495 8,353 7,362 7,837 7,749

Plant Net Heat Rate (HHV) Btu/kWh 6,866 6,786 7,079 7,352 7,135 7,479

Water Injection for NOx kpph - - 112 109 106 Control

C-3 Repowering Northport Repowering Attributes Feasibility Summary Study

Min Load Configuration - 7F.05 1x1 CCGT

CTG Load % 41% 42% 42% 50% 50% 50%

Evap Cooler Status On/Off Off Off Off Off Off Off

CTG Gross Output kW 105,816 101,118 95,418 134,566 125,814 117,221

STG Gross Output kW 82,065 75,779 69,453 88,541 82,342 76,563

Plant Gross Output kW 187,881 176,897 164,871 223,107 208,156 193,784

Plant Net Output kW 180,963 169,547 157,604 216,293 200,919 186,609

Auxiliary Load kW 6,918 7,350 7,267 6,814 7,237 7,175

Plant Net Heat Rate (HHV) Btu/kWh 6,795 6,655 6,992 6,979 6,801 7,189

Water Injection for NOx kpph 7,522 7,367 7,740 7,726 7,529 7,958 Control

EMISSIONS

Controlled at ISO Controlled at 15°F ambient

NOX lb/MMBTU 0.00724 0.02377

NH3 lb/MMBTU 0.00669 0.00732

CO lb/MMBTU 0.00442 0.00482

PM (including Ammonium lb/MMBTU 0.0066 0.01984 Sulfates)

SO2 lb/MMBTU 0.00136 0.00152

CO2 lb/MMBTU 115.67 161.89

ppm @ NOX 2 6 15% O2 ppm @ NH3 5 5 15% O2 ppm @ CO 2 2 15% O2

C-4 Repowering Northport Repowering Attributes Feasibility Summary Study

Northport Repowering – Phase 2 Estimated Performance

Configuration - 7F.05 2x0- SCGT

Fuel Natural gas Fuel Oil

Ambient Dry Bulb def F 15 59 92 15 59 92

Relative Humidity % 60 60 60 60 60 60

CTG Load % 100% 100% 100% 100% 100% 100%

Evap Cooler Status On/Off Off Off On Off Off On

CTG Gross Output kW 259,315 242,865 229,661 259,901 252,795 246,443

Plant Gross Output kW 518,630 485,730 459,322 519,802 505,590 492,886

Plant Net Output kW 508,693 476,159 450,022 512,399 498,266 485,630

Auxiliary Load kW 9,937 9,571 9,300 7,403 7,324 7,256

Plant Net Heat Rate (HHV) Btu/kWh 9,548 9,721 9,921 10,089 10,233 10,406

Water Injection for NOx kpph 0 0 0 282 278 275 Control

Part Load Configuration - 7F.05 2x0- SCGT

CTG Load % 75% 75% 75% 75% 75% 75%

Evap Cooler Status On/Off Off Off Off Off Off Off

CTG Gross Output kW 195,034 182,652 172,768 195,498 190,173 185,404

Plant Gross Output kW 390,068 365,304 345,536 390,996 380,346 370,808

Plant Net Output kW 381,521 357,118 337,522 384,300 373,711 364,225

Auxiliary Load kW 8,547 8,186 8,014 6,696 6,635 6,583

Plant Net Heat Rate (HHV) Btu/kWh 10,410 10,312 10,669 11,073 10,825 11,149

C-5 Repowering Northport Repowering Attributes Feasibility Summary Study

Water Injection for NOx kpph - - - 232 221 222 Control

Min Load Configuration - 7F.05 2x0- SCGT

CTG Load % 41% 42% 42% 50% 50% 50%

Evap Cooler Status On/Off Off Off Off Off Off Off

CTG Gross Output kW 105,818 101,123 95,420 129,363 126,105 117,489

Plant Gross Output kW 211,636 202,246 190,840 258,726 252,210 234,978

Plant Net Output kW 205,039 195,910 184,569 252,758 246,279 229,142

Auxiliary Load kW 6,597 6,336 6,271 5,968 5,931 5,836

Plant Net Heat Rate (HHV) Btu/kWh 13,263 12,502 13,252 13,107 12,366 13,045

Water Injection for NOx kpph - - - 181 166 163 Control

EMISSIONS

Controlled at ISO Controlled at 15°F ambient

NOX lb/MMBTU 0.00906 0.02378

NH3 lb/MMBTU 0.01339 0.01465

CO lb/MMBTU 0.01102 0.01448

PM (including Ammonium lb/MMBTU 0.0066 0.02035 Sulfates)

SO2 lb/MMBTU 0.00136 0.00152

CO2 lb/MMBTU 115.67 161.89

ppm @ NOX 2.5 6 15% O2 ppm @ NH3 10 10 15% O2 ppm @ CO 5 6 15% O2

C-6 Repowering Northport Repowering Attributes Feasibility Summary Study

Northport Repowering – Phase 3 SCGT Estimated Performance

Configuration - 7F.05 1x0- SCGT

Fuel Natural gas Fuel Oil

Ambient Dry Bulb def F 15 59 92 15 59 92

Relative Humidity % 60 60 60 60 60 60

CTG Load % 100% 100% 100% 100% 100% 100%

Evap Cooler Status On/Off Off Off On Off Off On

CTG Gross Output kW 259,315 242,865 229,661 259,901 252,795 246,443

Plant Net Output kW 254,319 238,051 224,983 256,175 249,108 242,790

Plant Aux Load Output kW 4,996 4,814 4,678 3,726 3,687 3,653

Plant Net Heat Rate (HHV) Btu/kWh 9,549 9,722 9,922 10,090 10,234 10,407 Water Injection for NOx kpph - - - 141 139 138 Control

Part Load Configuration - 7F.05 1x0- SCGT

CTG Load % 75% 75% 75% 75% 75% 75%

Evap Cooler Status On/Off Off Off Off Off Off Off

CTG Gross Output kW 195,041 182,658 172,775 195,504 190,179 185,411

Plant Net Output kW 190,740 178,537 168,739 192,132 186,836 182,094

Plant Aux Load Output kW 4,301 4,121 4,036 3,372 3,343 3,317

Plant Net Heat Rate (HHV) Btu/kWh 10,411 10,314 10,670 11,074 10,826 11,150

Water Injection for NOx kpph - - - 116 110 111 Control

Min Load Configuration - 7F.05 1x0- SCGT

CTG Load % 41% 42% 42% 50% 50% 50%

Evap Cooler Status On/Off Off Off Off Off Off Off

C-7 Repowering Northport Repowering Attributes Feasibility Summary Study

CTG Gross Output kW 105,818 101,123 95,420 129,363 126,078 117,489

Plant Net Output kW 102,492 97,927 92,256 126,354 123,087 114,546

Plant Aux Load Output kW 3,326 3,196 3,164 3,009 2,991 2,943

Plant Net Heat Rate (HHV) Btu/kWh 13,266 12,507 13,256 13,109 12,369 13,048

Water Injection for NOx kpph - - - 91 83 81 Control

EMISSIONS

Controlled at ISO Controlled at 15°F ambient

NOX lb/MMBTU 0.00906 0.02378

NH3 lb/MMBTU 0.01339 0.01465

CO lb/MMBTU 0.01102 0.01448

PM (including Ammonium lb/MMBTU 0.0066 0.02035 Sulfates)

SO2 lb/MMBTU 0.00136 0.00152

CO2 lb/MMBTU 115.67 161.89

ppm @ NOX 2.5 6 15% O2 ppm @ NH3 10 10 15% O2 ppm @ CO 5 6 15% O2

C-8 Repowering Northport Repowering Attributes Feasibility Summary Study

Northport Repowering - All Phases BESS Estimated Performance

Configuration - 50 MW x 4 hrs BESS

Attribute/ Assumption Measure Comments

BESS Rated Output (MW) 50 Levelized by annual augmentation

Total Hours in Year 8,760 Equals 365 x 24

Planned & Maintenance Outages (300) Average Expectation

Total Hour, Net of Outages 8,460 Net Hours

Estimated Availability 95% Typical Contract Requirement

Annual hours available 8,037 Factors in Availability

Annual days per year available 335 Days Available

Discharge Duration in hours 4 BESS Design Criteria

Annual Generation Hours 1,340 Assumes 1 cycle per day

Annual Generation in Mwhrs 67,000 Rated Output x Generation Hrs

Round Trip Efficiency 85% Assumed Performance

Charging Power in Mwhrs 78,824 Annual Charging Power

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D-1 Repowering Northport Repowering Project Feasibility Schedule: Scenario 3 Study

Appendix D: Northport Repowering Project Schedule (Scenario 3)

D-2 Repowering Northport Repowering Project Feasibility Schedule: Scenario 3 Study

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Repowering E-1 Feasibility Production Cost Methodology Study

Appendix E: Production Cost Methodology

Repowering E-2 Feasibility Production Cost Methodology Study

PRODUCTION COST METHODOLOGY

The need to reasonably accurately forecast total system production costs is critical in evaluating the potential benefits (or costs) associated with any proposed generating asset addition to LIPA’s portfolio. A variety of industry-standard tools and models were used to evaluate Northport. Specifically, those tools include Multi-Area Production Simulation (MAPS), a production cost simulation program developed by General Electric (GE) for utility planners. MAPS integrates highly detailed representations of a system’s load, generation, and transmission into a single simulation. This enables MAPS to calculate hourly production costs while recognizing the constraints imposed by the transmission system on the economic dispatch of generation. MAPS accurately simulates the operation of an interconnected power system in accordance with the least cost system dispatch, while respecting transmission limits and constraints. The program model can represent individual utilities and pools or combinations of both. All computations are performed while maintaining the chronology of the load model. Consequently, the MAPS model accounts for the load diversity present in the actual power system.

The MAPS model used consists of a representation of the 4-Pool system composed of New York, New , PJM Classic (New Jersey and parts of Pennsylvania), and parts of Canada (Hydro Quebec and parts of Ontario)). The model contains system load, generation, and transmission data for all utilities in the 4-Pool system.

In terms of load forecasting, a 20-year forecast is submitted by LIPA for review and approval to the New York Independent System Operator (NYISO), which subsequently publishes the approved forecast in the “Gold Book”. The forecast provides both annual peaks and energy requirements. For the rest of the areas in the 4-Pool model, the load is obtained from publications such as the Gold Book, PJM load report and ISO-NE’s Capacity, Energy, Loads and Transmission (CELT) report. To perform hourly unit commitment and dispatch, hourly load profiles are obtained from the Load Forecasting group (for Long Island) and GE (for the rest of the model).

The generation system data in MAPS includes generator unit characteristics, such as multi-step cost curves, variable O&M costs, unit cycling capabilities, emission rates, outage rates and market bids by unit loading block. The generation units, along with chronological hourly load profiles, are assigned to individual buses on the transmission system. The generation database is updated on an annual basis to reflect unit retirements, installations, and changes in existing generation. For units on Long Island that are under contract to LIPA, detailed and proprietary updates are internally provided. For the rest of the generation in the 4-Pool system, the data is obtained from publications, such as Gold Book and other publicly available sources.

Repowering E-3 Feasibility Production Cost Methodology Study

The transmission system is modeled in terms of individual transmission lines, interfaces (which are groupings of lines), phase-angle regulators (PARs), HVDC lines and various transmission system contingencies. The transmission model, known as load flow, is updated on an annual basis in coordination with NYISO. An annual system study – the Summer Operating Study - is performed to identify limitations on the transmission system and the impact of any system changes. Inputs regarding transmission configurations and limitations and assumptions regarding dispatch of supply resources are also incorporated into the load flow. A load flow analysis is then run that identifies locally constrained areas or areas that are at risk of being constrained in the near future. To reflect real system condition, these constraints are modeled in MAPS. In addition, LIPA’s contracts, such as Transmission Congestion Contracts (TCCs), and generation contracts are also individually modeled in MAPS. The result is a model that mimics the operation of LIPA’s system and provides an insight into the future generation profile.

MAPS commitment and dispatch process starts by creating a unit priority list. The priority list identifies the thermal generators that are available to serve the load during a particular hour. The order of the units within this list is based upon full load unit cost accounting for minimum down-time and minimum run-time constraints. Thermal generators that have been designated as "must-run" units have their minimum capacity committed first. The remainder of these units and the full capacity of all other units are then committed based upon economic order. This process continues until the sum of the continuous ratings of the committed units is greater than or equal to the load, and the sum of the maximum ratings of the committed units is greater than or equal to the load plus the required spinning reserve. Energy storage (ES) generators (such as pumped storage hydro or batteries) are committed next. Using the hourly commitment schedule and data provided from the load model, MAPS determines thermal unit cost curves to use in scheduling the ES units. The ES units are used to shave the peak loads. The ES units are operated until either the recharge costs exceed the incremental savings that result from peak shaving or storage limits are reached. Once the program has determined the energy storage schedule, the thermal unit commitment schedule is redeveloped using modified loads to reflect the ES recharging and generation. MAPS re-dispatches the thermal units on an hourly basis to meet the modified loads. Using the forced outage rates that have been defined for each of the thermal units and a random number generator, units are taken offline for random intervals for the year. This process is then repeated for the next study hour and continues until the conclusion of the Study Period.

For project evaluations, such as analyzing the impact of addition/retirement of generation, a reference model (case) is developed based on latest MAPS model and study assumptions. The reference case reflects the expected system conditions without the new project. A separate case with the project modeled is then developed from the reference case. Both cases are evaluated over a specific time frame, usually 20 years. Next, the two cases are compared to

Repowering E-4 Feasibility Production Cost Methodology Study

analyze the impact of the project on the system, such as changes to the other generation units on Long Island and purchases from the outside utilities; changes to the Long Island emissions; and/or financial production cost/savings. The production cost/savings are incorporated in a financial model that also uses other data, such as transmission costs, fixed costs, and capacity payments.

LAST PAGE OF APPENDIX E.

Repowering F-1 Feasibility Market Forecasting Methodology Study

Appendix F: Market Forecasting Methodology

Repowering F-2 Feasibility Market Forecasting Methodology Study

MARKET FORECASTING METHODOLOGY

A capacity model is used to assist in both the planning and management of LIPA’s resource needs and market requirements. The model, known as “Market Manager” is a Microsoft Excel based program which can perform both deterministic and probabilistic analyses when used in conjunction with @Risk, a Monte Carlo based statistics add-on for Excel produced by the Palisades Corporation. The following is a brief overview of the model, the different functions it performs and the outputs it provides for use in the areas of capacity resource planning and market management.

Load and Capacity Planning – Both load and supply data are entered into the model. The model uses the peak load forecast data approved by the New York Independent System Operator (“NYISO”) for use in the identification and planning of long and short-term resource needs. This forecast is published annually by NYISO in its Load & Capacity Data “Gold Book” and is generally a 20-year forecast for NYISO Zone “K” (Long Island). [NYISO also publishes load forecast data for New York City, Lower Hudson Valley and the NYCA, which is contained here and used for price determinations by the model]. Long Island uses two peak load forecasts, a NYCA coincident peak – used to calculate the Installed Reserve Requirement (“IRM”) and a Zone “K” non- coincident peak – used to calculate the Long Island Locational Requirement (“LI LCR”). The Zone “K” forecast is broken down by individual load components and programs (Demand Side Management, Retail Access, Feed in Tariffs, Municipalities, etc.) and then totaled to determine both Long Island and LIPA load and resource requirements. The IRM and LI LCR are determined by the New York State Reliability Council (NYSRC) and the NYISO, respectively, for the next calendar year. The IRM and LI LCR are forecasted beyond that by the service provider for the term of the load forecast. The model uses rating data for all Long Island based resources, including those under contract to LIPA as well as municipalities and merchant resources located in NYISO Zone “K”. Individual data inputs include seasonal DMNC data, COD & retirement dates, contract start & end dates, NYISO PTID and other unit characteristic information. The load and resource data is used by the model to determine annual capacity resource positions and requirements for Long Island and LIPA.

Capacity Price Forecasting – Market Manager is also used to forecast capacity market prices for both short term (monthly) and long term (annually) planning purposes. NYISO uses the Monthly “Spot” Capacity Prices (also known as the Demand Curve Prices) as the market indices or proxy prices for capacity in New York. There are four locality prices in New York - NYCA, Lower Hudson Valley, Long Island and New York City. These prices are calculated in the model. The model includes all generating resources located in New York State and combines them with annual NYISO Demand Curve parameters to generate a Monthly Demand Curve price forecasts for

Repowering F-3 Feasibility Market Forecasting Methodology Study

each of the four localities. The price forecast model also uses historical prices to identify trends which are used to help determine future prices in each of these areas.

Market Purchases, Budgeting and Cost Estimation – The model is also used to estimate the cost of additional capacity resources purchased in the NYISO markets that are required by LIPA to meet its Installed Reserve Margin and Long Island Locality Requirements on a monthly and annual basis. The model uses load and resource forecasts for NYCA and Long Island and allocates to LIPA a pro-rata share of the overall supply in the NYCA and Long Island Markets. Resources under contract to LIPA each month are netted from the final resource allocations with the remaining resource allocations priced at the values determined in the capacity pricing model. Changes in assumptions such as load, supply, market transactions and pricing parameters all impact the results in this area. The final result is an annual market purchase cost associated with these additional capacity purchases that is calculated on a monthly basis for both the NYCA and LI capacity markets and summarized annually.

Probabilistic Modeling – Market Manager operates in a default deterministic mode. The model also has the ability to operate in a stochastic mode which replaces all individual input variables with user defined probabilistic inputs sampled by a Monte Carlo simulation. The model operates in conjunction with @Risk software to generate and store all input and output data when the probabilistic mode of operation is selected. Distributions for load and supply variables can include normal, discrete, triangle, and a host of others including customized functions and dependent variables. Selected outputs that are displayed include load requirements, supply positions, resource needs, market costs, market price forecasts as well as many others. Probabilistic outputs are displayed in chart form (Confidence Intervals) as well as in graph form.

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